Roxas v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute involves multiple ejectment cases filed by Maximo Roxas, Angel Mantes, and Arturo del Prado against various private respondents. The petitioners, who are owners of parcels of land in San Juan, Rizal, alleged that the private respondents had been occupying these properties since February 1975 without paying rent and refused to vacate despite demands. The petitioners sought possession of the premises for their own use or for the use of immediate family members. In response, the private respondents filed a complaint for consignation and/or specific performance, seeking to compel the petitioners to accept rentals at a significantly lower rate. 2. Procedural History: The ejectment cases were initially filed in the municipal court of San Juan, Rizal. The private respondents' motion to dismiss for lack of jurisdiction was denied, as was their subsequent petition for certiorari with writ of preliminary injunction filed in the Court of First Instance of Rizal. Appeals of these dismissals to higher courts were also unsuccessful. After a joint trial, the Metropolitan Trial Court ruled in favor of the petitioners, ordering the private respondents to vacate and pay reasonable rentals and attorney's fees, while dismissing the private respondents' consignation complaint. This decision was affirmed in toto by the Regional Trial Court. However, the Intermediate Appellate Court (IAC) reversed the RTC's decision, dismissing the ejectment complaints, a ruling that was subsequently denied reconsideration by the IAC. 3. The Petition: The petitioners seek review of the IAC's decision and order, raising four main issues. They argue that Batas Pambansa Blg. 25, which excludes the sale of property as a ground for ejectment, should not apply retroactively to their acquisition of the properties seven years prior to the law's promulgation. They also contend that the private respondents' possession was by mere tolerance, which became illegal upon refusal to vacate, and that the IAC erred in ruling on the continuity of lease agreements. Furthermore, they challenge the IAC's interpretation of the requirement that lessors or their immediate family members must not own other available residential units for ejectment on grounds of personal use. Finally, they assert that the private respondents employed dilatory tactics to prevent them from enjoying their properties.
Issue(s)
Whether Batas Pambansa Blg. 25, excluding the sale of property as a ground for ejectment, is applicable despite the sale occurring seven years before its promulgation. Whether the possession of the private respondents was by mere tolerance, terminable anytime by the owner, or a continuity of lease from old to new owners. Whether the requirement for ejectment on the ground of personal use by the owner or immediate family necessitates that both the owner and the recipient must not own property suitable for dwelling purposes. Whether the private respondents employed dilatory tactics to prevent petitioners from enjoying their properties, including non-payment of rentals and subleasing.
Ruling
The Supreme Court granted the petition, reversed the decision of the Intermediate Appellate Court, and affirmed the decision of the Regional Trial Court. The Court ordered the private respondents to vacate the premises and pay rentals and attorney's fees.
Ratio Decidendi
On the applicability of Batas Pambansa Blg. 25: The Court reiterated its settled ruling in Santos v. Court of Appeals and other cases that the retroactive application of Batas Pambansa Blg. 25 to pending ejectment cases is permissible and no longer questionable. Therefore, the provisions of BP Blg. 25, including those excluding the sale of property as a ground for ejectment, were applicable to the case, even though the property was acquired by the petitioners seven years prior to the law's enactment. The Court emphasized that the law's application to pending cases was a settled matter. On possession by tolerance versus continuity of lease: The Court sustained the IAC's finding that although private respondents failed to pay rentals to subsequent owners, they remained tenants, and their possession was not converted into one by mere tolerance. Consequently, they could only be ejected on grounds provided under Batas Pambansa Blg. 25, as their monthly rentals did not exceed P300.00. The Court rejected the petitioners' contention that the cessation of rental payments automatically converted the possession into one by tolerance, citing Peran v. Hon. Presiding Judge. On the requirement of not owning suitable dwelling units: The Court clarified the requisites for ejectment under Section 5(c) of Batas Pambansa Blg. 25, which include the owner or immediate family member not owning any other available residential unit. The Court disagreed with the petitioners' interpretation that if the immediate family member does not own a unit, ejectment is permissible even if the owner-lessor does. The Court emphasized that the law requires the owner/lessor or the immediate member of the family to not own any available residential unit. The Court noted that petitioners Roxas and Mantes did not present evidence of owning other residential units, and petitioner del Prado's situation was also considered. The Court also highlighted that even if an owner possesses another unit, it would not be an obstacle if that unit is not available for use. On dilatory tactics and non-payment of rentals/subleasing: The Court found the plea regarding dilatory tactics well-taken. It observed that tenants often stop paying rentals while cases are pending, which is inequitable. The Court stated that when tenants fail to pay rentals beyond the grace period or as required by law, courts should not hesitate to suspend the rules and order ejectment, even if non-payment is not the original ground invoked. Similarly, if pending litigation, the tenant subleases the property without consent, the court should order ejectment in the interest of justice, as subleasing is another ground for ejectment under the law. The Court found that private respondents had not paid rentals since 1972 and admitted to subleasing the properties, justifying ejectment.
Main Doctrine
The Supreme Court reversed the IAC, affirming the RTC's decision to eject the private respondents. The Court held that the private respondents' possession was not by mere tolerance, but that they remained tenants whose possession could only be terminated on grounds provided by Batas Pambansa Blg. 25. However, the Court found that the petitioners' need for personal use of the property, coupled with the private respondents' failure to pay rentals and admitted subleasing, justified ejectment.