Bondoc v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Marcelo Bondoc had been occupying Apartment No. 3 of a commercial building since 1949, paying a monthly rental of P200.00 and operating a tailoring business. In 1974, the private respondent, Lorenzo Quiambao, who owned the building, purchased it and requested Bondoc to transfer to Apartment No. 4. Bondoc agreed, allegedly on Quiambao's assurance that he could continue leasing during the lessor's lifetime. Quiambao later allowed Bondoc to construct a temporary residential structure on a lot behind Apartment No. 4, owned by Quiambao, without charge, but with the condition that Bondoc would vacate upon request. In 1977, Quiambao asked Bondoc to vacate both the apartment and the lot. Bondoc refused, citing Quiambao's promise. Quiambao then filed a complaint for ejectment. Procedural History: The Municipal Circuit Court ruled in favor of Quiambao, ordering Bondoc to vacate. Bondoc appealed to the Regional Trial Court (RTC), which, while inferentially allowing ejectment from the apartment, ordered Quiambao to execute a new two-year lease contract for the lot. Bondoc filed a petition for certiorari with the Court of Appeals (CA), seeking dismissal of the ejectment complaint. The CA set aside the RTC's decision and reinstated the municipal court's ruling, ordering Bondoc to vacate Apartment No. 4 and the lot within sixty days, and authorizing Quiambao to demolish the structure if Bondoc failed to remove it. The Petition: Bondoc filed a petition for review with the Supreme Court, arguing that there was no valid reason for terminating the lease, as Quiambao's stated reasons (need for the premises and expiration of the lease) were inconsistent and that the latter reason was not timely raised. Bondoc also contended that the ruling in Salaria v. Buenviaje, which rejected the need for the premises as a valid reason for ejectment, was applicable.
Issue(s)
Whether the lease of commercial premises, being on a month-to-month basis, is terminable at the option of the lessor. Whether the alleged lifetime assurance given by the lessor constitutes a valid basis to prevent ejectment. Whether the lessee is entitled to retain possession of the lot and be reimbursed for improvements made on a temporary structure built on the owner's land, occupied only by tolerance.
Ruling
The petition is DENIED and the decision of the respondent court is AFFIRMED in toto, with costs against the petitioner. The decision is immediately executory.
Ratio Decidendi
On the terminability of the lease: The Court held that the lease of the disputed apartment was on a month-to-month basis, as indicated by the monthly rental payments. Consequently, it was terminable at the end of each month at the option of the lessor, in accordance with Article 1673 of the Civil Code. This provision allows judicial ejectment when the period agreed upon has expired. The Court clarified that the Salaria case, relied upon by the petitioner, was not applicable because it dealt with residential land, whereas the property in the present case was admittedly commercial in nature. Batas Pambansa Blg. 25, which prohibits ejectment for expiration of term in residential buildings, does not cover commercial lands. Therefore, the lease expired in accordance with Article 1687 of the Civil Code, which states that if the period for the lease has not been fixed, it is understood to be from month to month if the rent is monthly. On the alleged lifetime assurance: The Court found that the alleged promise of Quiambao to allow Bondoc to remain in the leased premises during the former's lifetime was not clearly established. The Court emphasized that for commercial leases, especially those on a month-to-month basis, such an assurance, if not clearly proven, cannot override the lessor's right to terminate the lease upon its expiration. The nature of the premises as commercial, as distinguished from residential, meant that it was not covered by special emergency legislation designed to protect residential tenants. On the lot and the temporary structure: The Court ruled that the lot on which Bondoc's house was located was never the subject of a lease. Bondoc occupied it only on Quiambao's tolerance and subject to its return upon demand. Furthermore, he was permitted to build only a temporary shelter, not the permanent structure he erected. The Court noted that Bondoc never specifically denied these allegations in the ejectment complaint, thus deeming them admitted. Consequently, Bondoc could not claim to be a builder in good faith nor demand payment for the improvements, nor could he retain the same until reimbursement.
Main Doctrine
A month-to-month lease of commercial premises is terminable at the end of each month at the option of the lessor, and the lessee cannot insist on remaining in possession based on an alleged lifetime assurance from the lessor, especially when the lease is commercial and not governed by emergency residential housing legislation.