Lesaca v. Cuevas
REITERATIONFacts
1. The Antecedents: Petitioner Eduardo M. Lesaca owned two properties leased on a month-to-month basis to respondent Tan Chun, with rentals payable in advance. Petitioner sought to increase the monthly rentals by 50%, later reduced to 25%. Respondent did not agree to the increased rates and continued to pay the old rates. Petitioner's counsel sent letters demanding payment of the increased rental or vacation of the premises, stating the lease was terminated effective May 1975. 2. Procedural History: Petitioner filed an ejectment case in the City Court of Manila, which ruled in his favor. Respondent appealed to the Court of First Instance (CFI) of Manila, which reversed the City Court's decision, finding it without jurisdiction because no proper demand to vacate, as required by law, was made. The Court of Appeals, finding only a question of law, certified the case to the Supreme Court. 3. The Petition: This is a petition for review. Petitioner argues that the month-to-month lease automatically terminated upon respondent's refusal to pay the increased rental, thus rendering the demand requirement under Section 2, Rule 70 of the Rules of Court inapplicable. Petitioner contends that the action was for termination of the lease due to expiration, not for failure to pay rent or comply with lease conditions. The core issue is whether the demand to vacate, as required by law, was necessary under these circumstances.
Issue(s)
Whether the demand to vacate provided under Section 2, Rule 70 of the Rules of Court is required in an ejectment case involving a month-to-month lease where the lessor proposed an increase in rental. Whether the letter demanding payment of increased rental or to vacate the premises constitutes a sufficient demand under Section 2, Rule 70 of the Rules of Court.
Ruling
The decision of the Court of First Instance and its order denying the motion for reconsideration are reversed and set aside. Respondent Tan Chun and all persons claiming under him are ordered to vacate the premises and restore possession to the petitioner. The judgment of the City Court of Manila is reinstated.
Ratio Decidendi
On the requirement of demand to vacate in a month-to-month lease with proposed rental increase: The Supreme Court held that a month-to-month lease contract provides for a definite period and may be terminated at the end of any month. When the respondent refused to pay the increased rentals for May 1975, the lease contract was deemed terminated. This termination was based not only on the lessor's letters informing the lessee of the lease termination effective May 1975 but more significantly on the lessee's refusal to pay the increased rate while remaining in the premises. The Court reiterated the principle that the owner of leased land has the right to terminate the lease at its expiration and to demand a new rate of rent, giving the tenant the option to accept the new rent or vacate. By refusing to do either, the lessee becomes a deforciant who can be judicially ousted without the need for a demand. On the sufficiency of the demand letter: The Court distinguished the present case from Vda. de Murga v. Chan, where a more definite demand was necessary because the lease contract had provisions for automatic renewal. In the instant case, the petitioner had the right to terminate the lease at the end of every month, which he did in May 1975 when the lessee refused to pay the increased rentals. Therefore, the lessee had the alternative to vacate, and his refusal made him a deforciant who could be ousted judicially without the need for a more specific or unconditional demand to vacate. The Court further stated that even if a demand were needed, the alternative demand to pay the increased rental or to vacate the premises is sufficient under the law to enable the lessor to bring an ejectment case, as the lessee had no legal right to remain in the premises upon the expiration of the lease contract in May 1975. The demand made by the petitioner was construed similarly to the demand in PNB v. Animas, where a demand to vacate or deliver the fruits of the land was deemed sufficient to make the possessor's occupation illegal.
Main Doctrine
In a month-to-month lease, the owner has the right to terminate the lease at the end of any month, and if the lessee refuses to pay the increased rental or vacate the premises, the lessee becomes a deforciant who can be judicially ousted without the need for a more specific or unconditional demand to vacate.