Spouses Santos v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, spouses Lazaro and Teodora Paragua, have been renting a one-door apartment since 1964. In 1972, they purchased a three-door apartment building, one unit of which was occupied by petitioners, spouses Miguel and Albina Santos, and another by petitioners, spouses Genaro and Elisa del Rosario, under verbal lease contracts for P190.00 monthly rental each. The private respondents asserted they bought the building to have a residence for their large family. In 1974, they advised petitioners to vacate so they could demolish the building and construct their residence. Petitioners refused, invoking Presidential Decree No. 20 and alleging the private respondents' true motive was to force an increase in rent from P190.00 to P250.00, and that the demolition plan was a ruse. Procedural History: Private respondents filed two separate ejectment cases against petitioners in the City Court of Manila. The City Court ruled in favor of the private respondents, ordering petitioners to vacate. Petitioners appealed to the Court of First Instance (CFI) of Manila, which affirmed the City Court's decision with a modification setting a specific date for vacation. After the CFI denied their motion for reconsideration, petitioners filed a petition for review with the Court of Appeals (CA), which dismissed it outright. The CA denied their motion for reconsideration, leading to the instant petition for review before the Supreme Court. A temporary restraining order was issued by the Supreme Court. The Petition: Petitioners contended that private respondents lacked a valid cause for ejectment under Presidential Decree No. 20, arguing that the alleged need for personal use of the property was not a sanctioned ground, especially in light of Memorandum Circular No. 970. They questioned the sincerity of the private respondents' claim of intending to reconstruct, insisting the ejectment was merely a response to their refusal to pay increased rent.
Issue(s)
Whether the need of the owner/lessor for the property for their own use is a valid ground for ejectment under existing laws. Whether Batas Pambansa Blg. 25, enacted during the pendency of the appeal, can be applied retroactively to the present case. Whether the private respondents' intention to demolish and reconstruct the building for their own residence was a mere pretext to eject the petitioners.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the ejectment of the petitioners from the premises. The Court found that while Presidential Decree No. 20 and Memorandum Circular No. 970 did not expressly provide for the owner's need for personal use as a ground for ejectment, the subsequent enactment of Batas Pambansa Blg. 25, which repealed PD 20, explicitly included this as a valid ground. The Court also found sufficient evidence to support the private respondents' sincere intention to demolish and reconstruct the building for their family's residence.
Ratio Decidendi
On the issue of the owner's need for the property as a ground for ejectment: The Court acknowledged that Presidential Decree No. 20 and Memorandum Circular No. 970 did not explicitly list the owner's need for personal use as a ground for ejectment. However, the Court emphasized that on April 20, 1979, Batas Pambansa Blg. 25 was enacted, repealing PD 20. BP Blg. 25, specifically Section 5(c), expressly provided that the need of the owner/lessor to repossess the property for his own use or for the use of any immediate member of his family as a residential unit is a valid ground for judicial ejectment, subject to certain conditions such as lease expiration, advance notice, and actual occupancy for at least one year. This provision directly addressed and resolved the petitioners' contention regarding the lack of a valid ground for ejectment based on the owner's personal need. On the retroactive application of Batas Pambansa Blg. 25: The Court held that the retroactive application of Batas Pambansa Blg. 25 to pending ejectment cases is a settled matter and can no longer be questioned. The Court cited previous rulings, including Alejandro Melchor, Jr., etc. vs. Hon. Jose L. Moya, etc, et al. (G.R. No. L-35256, March 17, 1983), Gutierrez vs. Cantada (90 SCRA 1), Onchengco vs. City Court of Zamboanga (95 SCRA 313), and Betts vs. Matias (97 SCRA 439), to support the principle that procedural laws and laws that provide new grounds for existing actions, like BP Blg. 25 in ejectment cases, are generally applied retroactively to cases pending before the courts. This established jurisprudence allowed the Court to apply the new grounds for ejectment provided by BP Blg. 25 to the case at bar, even though the initial actions were filed under PD 20. On the sincerity of the private respondents' intention to reconstruct: The Court found no merit in the petitioners' claim that the private respondents' plan to convert the apartment into a residential house was a mere pretext. The Court pointed to substantial evidence presented by the private respondents, which had been detailed in the Court of First Instance's decision. This evidence included a demolition permit issued by the Office of the City Engineer, applications for construction/repair, official receipts for building permits, approved renovation plans, certifications from suppliers and contractors, cost breakdowns, construction schedules, bank deposit statements showing significant funds, a sworn certification binding the owner to start construction and occupy the premises, and sworn certifications from owners of other properties where the private respondents' children were renting, indicating the need for the family to consolidate their residence. These documents collectively demonstrated a genuine and well-documented intention to proceed with the demolition and construction for their family's use.
Main Doctrine
The need of the owner/lessor to repossess the property for his own use or for the use of any immediate member of his family as a residential unit, provided certain conditions are met, is a valid ground for judicial ejectment under Batas Pambansa Blg. 25, which has retroactive application to pending ejectment cases.