Acab v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a residential lot owned by Jose R. Acab, leased verbally in 1942 to Amparo C. Villanueva and her husband for a monthly rental of fifty pesos (P50.00). Following the death of Jose R. Acab, his children, the petitioners herein, acquired ownership of the property through purchase from their father on July 3, 1989, and were issued a Transfer Certificate of Title. Despite the change in ownership, the lease continued on a month-to-month basis. 2. Procedural History: On April 10, 1991, the petitioners notified the private respondent, Amparo C. Villanueva, of their intention not to renew the lease and demanded that she vacate the premises within three months, citing their need for personal use of the property. When the private respondent refused to vacate, the petitioners, after obtaining a Certification to File Action from the barangay, filed an ejectment case with the Metropolitan Trial Court (MTC) of Kalookan City. The MTC ruled in favor of the petitioners, finding the month-to-month lease to have been validly terminated. The Regional Trial Court (RTC) affirmed the MTC's decision. However, the Court of Appeals reversed the lower courts' rulings, dismissing the ejectment case, reasoning that the petitioners failed to prove their need for the property and that ejectment solely based on the termination of a month-to-month lease was not justified. 3. The Petition: The petitioners filed this petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals erred in its decision and that the case was not decided in accordance with law and applicable jurisprudence. They contend that a month-to-month lease, as established by Article 1687 of the Civil Code and Batas Pambansa Blg. 877, is a lease with a definite period, and its expiration, coupled with proper notice to vacate, constitutes sufficient grounds for judicial ejectment under Section 5(f) of Batas Pambansa Blg. 877.
Issue(s)
Whether private respondent may legally be ejected from the subject property on the sole basis of the expiration of the verbal lease agreement under which rentals are paid monthly. Whether a month-to-month lease agreement, under Article 1687 of the Civil Code, is considered a lease with a definite period that can be terminated upon proper notice and demand for vacation.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Court of Appeals, and reinstated the decisions of the Metropolitan Trial Court and the Regional Trial Court. The Court ruled that private respondent may legally be ejected from the subject property.
Ratio Decidendi
On whether private respondent may legally be ejected from the subject property on the sole basis of the expiration of the verbal lease agreement under which rentals are paid monthly: The Court held that private respondent may be legally ejected. It clarified that Section 6 of Batas Pambansa Blg. 877 does not suspend the effects of Article 1687 of the Civil Code. Article 1687 provides that if the rent is paid monthly and no period for the lease has been set, the lease is considered to be on a month-to-month basis. The Court has consistently held that such leases are for a definite period and expire after the last day of any given thirty-day period, upon proper demand and notice by the lessor to vacate. In this case, all three lower courts found that the lease was on a month-to-month basis and that proper notice for non-renewal and demand to vacate were made by the petitioners. Therefore, the verbal lease agreement was validly terminated, providing sufficient cause for ejectment under Section 5(f) of Batas Pambansa Blg. 877, which lists the expiration of the lease contract as a ground for judicial ejectment. On whether a month-to-month lease agreement, under Article 1687 of the Civil Code, is considered a lease with a definite period that can be terminated upon proper notice and demand for vacation: The Court affirmed that a month-to-month lease under Article 1687 is considered a lease with a definite period. This is because the lease expires at the end of each monthly term, unless renewed. The Court cited previous rulings, such as Uy Hoo and Sons Realty Development Corporation v. Court of Appeals, which held that a month-to-month lease under Article 1687 is a lease with a definite period, the expiration of which, upon previous demand by the lessor to vacate, can justify ejectment. The Court further noted that since a month-to-month lease is considered to have a definite period, it falls within the exception provided in Section 6 of Batas Pambansa Blg. 877, making Article 1673(1) of the Civil Code applicable. This article allows judicial ejectment when the period agreed upon or that which is fixed for the duration of leases under Article 1687 has expired.
Main Doctrine
A month-to-month lease agreement, under Article 1687 of the Civil Code, is considered a lease with a definite period, which expires after the last day of any given thirty-day period upon proper notice and demand by the lessor to vacate, thereby providing sufficient cause for ejectment under Section 5(f) of Batas Pambansa Blg. 877.