Rantael v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent Teresa F. Llave leased a unit to petitioner Roberto Rantael on a month-to-month basis starting May 1970. In July 1973, Llave attempted to increase the rent, leading Rantael to file a complaint. A settlement was reached, formalizing the lease through a written "Agreement on Occupancy of Apartment" on August 1, 1974, which stipulated month-to-month occupancy and allowed termination by either party upon thirty (30) days' notice. Procedural History: Llave inquired with the Office of the President regarding her right to terminate the lease, and was advised that the lease was for a definite period and thus exempt from PD 20. Subsequently, Llave notified Rantael of her decision to terminate the lease. Upon Rantael's refusal to vacate, Llave filed an ejectment suit. The City Court ruled in favor of Llave, ordering Rantael to vacate. The Rizal Court of First Instance affirmed the decision. The Court of Appeals dismissed Rantael's petition for review. The Petition: Rantael filed a petition for review on certiorari with the Supreme Court, disputing the Court of Appeals' ruling that the lease agreement provided for a definite period, thus exempting it from PD 20.
Issue(s)
Whether the Agreement on Occupancy of Apartment, stipulating a month-to-month basis and termination upon thirty (30) days' notice, provides for a definite period for the lease. Whether the lease agreement falls under the exception provided in Section 4 of Presidential Decree No. 20, allowing for judicial ejectment. Whether Batas Pambansa Blg. 25, which superseded PD 20, supports the lessor's right to judicially eject the lessee.
Ruling
The Supreme Court dismissed the petition for review on certiorari, affirming the decision of the Court of Appeals. The Court held that the lease agreement provided for a definite period and thus fell under the exception to PD 20, allowing for judicial ejectment. The Court also noted that Batas Pambansa Blg. 25 further supports the lessor's right to eject.
Ratio Decidendi
On the issue of whether the lease agreement provides for a definite period: The Court ruled that the "Agreement on Occupancy of Apartment" clearly provided for a definite period. The stipulation "beginning today" established the commencement date, and the phrase "on a month to month basis" coupled with the express provision allowing termination upon thirty (30) days' notice by either party defined the duration and termination. The Court interpreted "month" as a period of thirty days, consistent with Article 12 of the Civil Code. This contractual arrangement, with its defined start and termination conditions, constituted a definite period, distinguishing it from leases governed by Articles 1682 and 1687 of the Civil Code where the period is not fixed by the parties. On the applicability of Presidential Decree No. 20: The Court held that Section 4 of PD 20 explicitly provides an exception for leases with a definite period. Since the lease agreement in this case was determined to have a definite period, it fell under this exception. Consequently, the general rule suspending the right of judicial ejectment upon expiration of the period did not apply. The lessor, respondent Llave, was therefore entitled to exercise her prerogative to terminate the lease and judicially recover possession of the premises. On the relevance of Batas Pambansa Blg. 25: The Court noted that Batas Pambansa Blg. 25, which superseded PD 20, also provides grounds for judicial ejectment. Specifically, Section 5(c) allows ejectment when the owner needs the property for his own use or for a member of his family, provided the lease period has expired, and Section 5(f) allows ejectment upon the expiration of the period of a written lease contract. The Court found that the expiration of the definite period of the lease, as established by the agreement, satisfied this ground. The Court also found merit in Llave's stated reason for seeking possession, which was to provide housing for her son, as supported by her testimony and letters.
Main Doctrine
A lease agreement providing for a month-to-month occupancy with a stipulation that either party may terminate the agreement upon thirty (30) days' notice constitutes a lease with a definite period, thereby falling under the exception to Presidential Decree No. 20, allowing for judicial ejectment.