Fuente v. Borromeo
REITERATIONFacts
The Antecedents: Narcisa de la Fuente and Jose Teodoro (plaintiffs-appellees) filed an action against Luis Borromeo (defendant-appellant) to eject him from the premises at 759 San Sebastian Street, Manila. The plaintiffs-appellees sought possession of the property, monthly rent of P40 from March 1, 1945, until the property is vacated, and costs. Procedural History: The Municipal Court and the Court of First Instance of Manila both ruled in favor of the plaintiffs-appellees, ordering the defendant-appellant to vacate the premises and pay the stipulated rent. The defendant-appellant appealed the decision. The Petition: The defendant-appellant alleged that the trial court abused its discretion in denying his motion for postponement, despite submitting a medical certificate. He also contested the period for which back rentals were claimed.
Issue(s)
Whether the trial court gravely abused its discretion in denying the motion for postponement. Whether the defendant-appellant is liable for rentals from March 1, 1945, or from March 11, 1945.
Ruling
The Supreme Court affirmed the decision of the lower courts in ordering the defendant-appellant to vacate the premises. However, it modified the award of back rentals, ordering payment from March 11, 1945, instead of March 1, 1945. No pronouncement as to costs was made.
Ratio Decidendi
On the denial of the motion for postponement: The Court held that the trial court did not abuse its discretion in denying the defendant-appellant's motion for postponement. The motion was accompanied by a medical certificate that was not duly sworn, failing to meet the requirements of Rule 31, Section 6 of the Rules of Court and established jurisprudence. The appellant's reliance on the case of Natividad v. Marquez was misplaced as that case required a satisfactory sworn statement from a physician. Furthermore, the appellant had already secured one postponement and failed to appear on the rescheduled hearing date without a proper medical certificate, thus not being deprived of his right to be heard. On the period for back rentals: The Court acknowledged the moratorium order (Executive Order No. 25, as amended by Executive Order No. 32) which stipulated that only rentals from March 11, 1945, onwards were exigible. The City of Manila was liberated from enemy occupation on March 10, 1945. Therefore, the defendant-appellant should not have been condemned to pay rentals from March 1, 1945, but only from March 11, 1945. The lease agreement was on a month-to-month basis, and while Article 1581 of the Civil Code allows termination without special notice upon the expiration of the term, the plaintiff had sent letters requesting vacation. The Court reiterated that while it is aware of the housing crisis, it cannot sanction procedures that unduly delay justice.
Main Doctrine
The Court affirmed the ejectment order but modified the period for which back rentals were due, applying the moratorium order. It also held that the denial of a motion for postponement due to a non-juridical medical certificate did not constitute grave abuse of discretion.