Heirs of Fausta Dimaculangan v. Intermediate Appellate Court and Felimon Uy
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an ejectment case initiated by Felimon Uy against Fausta Dimaculangan, the lessee of an apartment at P260.00 per month since 1961. Uy, having purchased the property, sought to increase the rent significantly and demanded a new lease agreement. Dimaculangan contested the rent increase, asserting it violated rent control laws, and claimed she had attempted to pay her rent, which was allegedly refused. 2. Procedural History: The ejectment complaint was filed with the Pasay City Court, Branch II. Following Fausta Dimaculangan's death during the proceedings, her children were substituted as defendants. The City Court, on October 16, 1980, decided to increase the monthly rental and set a definite lease period. This decision was affirmed on appeal by the Regional Trial Court, Branch CXIII, Pasay City. Subsequently, the Intermediate Appellate Court dismissed the petition for review filed by the heirs of Dimaculangan. 3. The Petition: The petitioners, the heirs of Fausta Dimaculangan, seek review on certiorari of the Intermediate Appellate Court's decision. They raise issues concerning the trial court's authority to increase agreed-upon rentals and alter the lease period from indefinite to a fixed term, arguing these actions violate existing laws, specifically Presidential Decree No. 20 and Batas Pambansa Blg. 25. They also question whether the Intermediate Appellate Court committed a grave abuse of discretion in dismissing their petition for review.
Issue(s)
Whether the trial court, in an ejectment case, may increase the agreed rental amount without violating existing laws, and whether the trial court may alter the parties' agreement by shortening the lease period from an indefinite period, within the purview of Presidential Decree No. 20 and Batas Pambansa Blg. 25, to a fixed two-year term. Whether the Intermediate Appellate Court committed a grave abuse of discretion amounting to lack or absence of jurisdiction, or at least a grave reversible error of law and/or fact and law, in dismissing the petition for review.
Ruling
The petition is dismissed for lack of merit. The issues raised have become moot and academic.
Ratio Decidendi
On the issue of whether the trial court may increase the rental and alter the period of the lease: The Court found that the lease contract was covered by Presidential Decree No. 20 (P.D. 20) and later by Batas Pambansa Blg. 25 (B.P. 25). The decisive issue was whether the lease was for a definite period to determine the applicability of P.D. 20. The Court reiterated its ruling that leases where rentals are paid monthly are deemed on a "month-to-month basis." Such leases provide for a definite period and may be terminated at the end of any month. By express exception of P.D. 20, judicial ejectment lies when the lease is for a definite period or when the fixed or definite period agreed upon has expired. The Court further noted that subsequent laws, like Batas Pambansa Blg. 877, have erased the distinction between oral and written leases concerning expiration of the lease period as a ground for judicial ejectment. Therefore, at the time of filing the action, the private respondent had a clear right to eject the petitioners as the lease period expired at the end of every monthly period. Consequently, the issues regarding the trial court's authority to increase rentals and alter the lease period became moot and academic. On the issue of whether the IAC committed grave abuse of discretion: Given that the substantive issues regarding the lease period and rental increase were rendered moot and academic, the IAC's dismissal of the petition for review was justified. The Court also addressed the IAC's ruling that the petition was moot due to the death of the lessee, Fausta Dimaculangan. While the IAC cited Mabalot v. Madela Jr., the Supreme Court clarified that lease is not essentially personal and is transmissible to heirs, distinguishing the present case from Mabalot where only household members sought to continue possession. However, this distinction did not alter the outcome as the fixed period set by the respondent judge had already expired in 1982, rendering the issue moot. The Court also noted that the period fixed by the judge, which appeared acceptable to the lessor, had expired, and this was within the lessor's authority to terminate the contract and enter into a new one.
Main Doctrine
A lease contract on a month-to-month basis provides for a definite period and may be terminated at the end of any month, thus falling outside the suspension of ejectment provisions under Presidential Decree No. 20.