Cortez v. Camilon
REITERATIONFacts
The Antecedents: Spouses Ricardo and Lourdes Cortez were lessees of an apartment located at 4541-D Quintos Street, Makati, Metro Manila. The lease was on a month-to-month basis. The lessor, Recaredo Coronel, needed the apartment for the use of his daughter, Grace Coronel-Valdez, who was residing with her in-laws on the same street. Procedural History: The Makati municipal court ordered the ejectment of the Cortez spouses. This decision was affirmed by the Court of First Instance of Rizal, Pasig Branch VIII. The Appeal: The Cortez spouses appealed to the Supreme Court, contending that the ground for ejectment based on the owner's need for the property applies only to leases with a fixed period that has expired, and not to their month-to-month lease, which they argued had not expired and for which ejectment on that ground was suspended.
Issue(s)
Whether the need of the owner or an immediate member of his family for the leased residential unit is a valid ground for ejectment in a month-to-month lease, notwithstanding the suspension of ejectment based on lease expiration under Presidential Decree No. 20 and Batas Pambansa Blg. 25. Whether the lessor's demand to vacate and subsequent filing of an ejectment suit, based on the need for the property, constitutes a valid termination of the month-to-month lease for the purpose of invoking the owner's need as a ground for ejectment.
Ruling
The Supreme Court affirmed the decision of the lower court ordering the ejectment of the Cortez spouses. The Court held that the lessor's need for the apartment for his daughter's use is a legitimate ground for ejectment, even in a month-to-month lease, provided the statutory requirements are met. The Court dismissed the contention that this ground is only applicable to fixed-term leases that have expired.
Ratio Decidendi
On Issue 1: The Supreme Court held that the need of the owner or an immediate member of his family for the leased residential unit is a valid ground for ejectment, even in a month-to-month lease. The Court clarified that while Presidential Decree No. 20 suspended ejectment based on the expiration of the lease period for dwelling units, it did not suspend other grounds for ejectment provided under the Civil Code and Batas Pambansa Blg. 25. Specifically, Section 5(c) of Batas Pambansa Blg. 25 explicitly lists the need of the owner/lessor or an immediate member of his family for the property as a ground for judicial ejectment, provided certain conditions are met, such as the owner/lessor not owning any other available residential unit and the intent to occupy the unit for at least one year. The Court found that the lessor's need for his daughter's use fell under this provision. On Issue 2: The Supreme Court ruled that the lessor's demand to vacate dated June 4, 1979, and the subsequent filing of the ejectment suit in September 1979, effectively terminated the month-to-month lease for the purpose of invoking the owner's need as a ground for ejectment. The Court reasoned that while a month-to-month lease does not have a fixed expiration date in the same way a fixed-term lease does, it can still be terminated by the lessor. The ground for ejectment invoked was not the expiration of the lease period, which is suspended under PD 20, but rather the lessor's legitimate need for the property. This need, coupled with the proper notice and intent to occupy, constituted a valid basis for the ejectment suit, irrespective of the month-to-month nature of the lease.
Main Doctrine
The Supreme Court affirmed the ejectment of the lessees from a residential unit, holding that the lessor's need for the property for his daughter's use is a legitimate ground for ejectment under Batas Pambansa Blg. 25, even if the lease was on a month-to-month basis. The Court clarified that while Presidential Decree No. 20 suspended the expiration of lease periods as a ground for ejectment, other grounds, such as the owner's need for the property, remain valid, provided the statutory requirements, including advance notice and intent to occupy, are met. The contention that this ground only applies to fixed-term leases that have expired was deemed fallacious.