Medina v. Court of Appeals
REITERATIONFacts
The Antecedents: In 1974, Dominga Hipolito (mother of petitioner Emiliana Medina) orally leased an apartment unit in Tondo, Manila, from Rosa Laqui. Dominga and her family continuously occupied the premises and paid monthly rentals. After Dominga's death in February 1990, her family, including petitioner, continued to occupy the apartment. On May 15, 1990, Rosa Laqui, through her agent, notified petitioner of a rental increase from P729.35 to P1,500.00 per month, effective June 1990. Petitioner refused to pay the increased amount, insisting it violated the prevailing Rental Law, and instead tendered payments with the 20% increase allowed by law. Rosa refused these payments. Consequently, petitioner deposited rentals for August, September, and October 1990 with the Barangay Treasurer and filed an action for consignation on November 2, 1990. In her answer, Rosa claimed her son, Ruben Laqui (private respondent), was the owner. However, rental receipts and MERALCO bills indicated Rosa as the lessor. Procedural History: On November 27, 1990, Ruben Laqui sent a demand letter to petitioner, stating she occupied his apartment without his knowledge or consent and had not paid rent since Dominga's death, and demanding she vacate within ten days, citing his brother's need for the unit. Petitioner disregarded the letter, prompting Ruben to file an unlawful detainer case on January 7, 1991. The Metropolitan Trial Court (MTC) dismissed the case for lack of cause of action. The Regional Trial Court (RTC) reversed the MTC decision, ordering petitioner to vacate, pay back rentals, and attorney's fees. Petitioner appealed to the Court of Appeals (CA), which affirmed the RTC decision with modification, reducing the back rentals. The CA ruled that ejectment was justified due to arrears in rent and improper consignation. Meanwhile, the MTC decided the consignation case in favor of petitioner, which the RTC affirmed. Rosa Laqui did not appeal this decision. The Petition: Petitioner filed the instant petition with the Supreme Court, challenging the CA's decision, alleging errors in failing to rule that Rosa Laqui owned the property, that the reason for ejectment (lessor's brother's need) was invalid under the Rent Control Law, that the lease period had not expired, and that there were no rental arrears due to the lessor's refusal to accept payment and the subsequent consignation.
Issue(s)
Whether the private respondent, Ruben Laqui, is the proper party to institute the unlawful detainer case and whether he is the owner of the leased premises. Whether the reason for ejectment, namely the need of the lessor's brother for the premises, is a valid ground under the Rent Control Law. Whether the lease contract, being oral and without a definite period, has expired or is terminable under the Rent Control Law. Whether the petitioner was in arrears in the payment of rentals, considering the lessor's refusal to accept payment and the subsequent consignation.
Ruling
The Supreme Court granted the petition, reversed the decisions of the Court of Appeals and the Regional Trial Court, and reinstated the decision of the Metropolitan Trial Court dismissing the unlawful detainer case. The amount deposited by the petitioner with the Branch Clerk of Court was ordered to be released to the private respondent. No costs were awarded.
Ratio Decidendi
On the issue of ownership and the proper party to sue: The Court acknowledged that the private respondent presented a Transfer Certificate of Title and tax declarations in his name, establishing his ownership. However, it noted that the private respondent only asserted his ownership on November 27, 1990, after the consignation case was filed. Prior to this, his mother, Rosa Laqui, consistently acted as the owner-lessor, collecting rentals and even demanding an increase. The Court found that Rosa Laqui's acts bound the private respondent, especially since he claimed she administered the property until June 1990 and implicitly recognized Dominga Hipolito as his lessee. Furthermore, the private respondent himself, in his pleadings, admitted that the agreement was on a month-to-month basis, thereby acknowledging petitioner as his lessee. The Court held that the private respondent was estopped from disowning Rosa's acts and that he had belatedly recognized the petitioner as his lessee. On the validity of the ground for ejectment (lessor's brother's need): The Court agreed with the petitioner that a brother is not an immediate member of the family as defined under Section 2(c) of Batas Pambansa Blg. 877 (Rent Control Law). The law limits immediate family members to spouse, direct descendants, or ascendants. Therefore, the private respondent's claim that he needed the premises for his brother was not a valid ground for ejectment under the said law. The Court emphasized that the private respondent's demand letter primarily anchored the repossession on his brother's need, despite also mentioning non-payment of rentals. On the expiration of the lease period: The Court reiterated the ruling in Miranda v. Ortiz and Rivera v. Florendo, stating that while Article 1673 of the Civil Code is suspended by the Rent Control Law, Article 1687, which allows for the determination of lease periods, is not. Since the lease was on a month-to-month basis, it was terminable at the end of any month upon proper notice. The Court noted that the private respondent's demand letter, dated November 27, 1990, served as notice to vacate. However, this was rendered moot by the other findings regarding the validity of the grounds for ejectment and the rental payments. On the arrears in rentals and the validity of consignation: The Court found that the petitioner's consignation of rentals was ineffective. The rentals for August to October 1990 were deposited with the Barangay Treasurer, which is not one of the entities authorized under Section 5(b) of B.P. Blg. 877 (court, city/municipal treasurer, or bank). Furthermore, the deposit was made more than one month after the lessor's refusal to accept payment. The Court also noted that no further deposits were made until September 23, 1991. Despite the invalidity of the consignation, the Court ruled that the private respondent could not use non-payment of rentals as a ground for ejectment because his demand letter was based on his brother's need and he had initially denied that the petitioner was his lessee. The Court stated that the private respondent studiously avoided using non-payment of rentals as a ground because it would clash with his theory that the petitioner was not his lessee.
Main Doctrine
A lessor who demands repossession based on personal need but later claims non-payment of rent, and whose demand letter fails to establish the petitioner as a lessee, cannot validly eject the petitioner on the grounds of non-payment of rent, especially when the petitioner has initiated a consignation case and the lessor has belatedly acknowledged the month-to-month lease. Furthermore, a brother is not considered an immediate member of the family for purposes of repossession under the Rent Control Law.