Santos v. Alvarez
REITERATIONFacts
The Antecedents: Plaintiff-appellee Alejandro R. Santos filed an ejectment suit for premises at No. 22, Altura Street, Sta. Mesa, Manila, occupied by defendants-appellants Catalina de Alvarez, Carlos Tanseco, and Manuel Alvarez since September 1942. The municipal court ruled in favor of Santos, which was affirmed by the Court of First Instance. The defendants appealed the judgment ordering them to vacate, pay back rent from April 1, 1945, at P35 per month, and costs. Procedural History: The municipal court rendered judgment for the plaintiff. The Court of First Instance affirmed this judgment on appeal. The defendants then appealed to the Supreme Court. The Petition: The defendants-appellants are seeking to reverse the judgment of the Court of First Instance ordering them to vacate the premises and pay back rents and costs.
Issue(s)
Whether Commonwealth Act No. 66, amending Commonwealth Act No. 689, applies to pending cases and can be given retroactive effect. Whether the lessor's desire to have the premises occupied by his sons or near relatives constitutes a valid ground for ejectment under the law. Whether the defendants' non-payment of rent was willful and deliberate.
Ruling
The judgment of the lower court is affirmed in so far as it fixes the monthly rent at P35, but reversed regarding the order to vacate and pay costs. Plaintiff-appellee will pay the costs of the suit.
Ratio Decidendi
On the applicability and retroactivity of Commonwealth Act No. 66: The Court held that Section 2 of Republic Act No. 66, amending Commonwealth Act No. 689, provides a valid defense against ejectment if rents are unjust and unreasonable, and generally prohibits ejectment except for willful and deliberate non-payment or when the lessor needs to occupy the building. This provision is applicable to pending cases and can be given retroactive effect as an emergency measure enacted under the police power to address the scarcity of housing facilities. The purpose of the law is to relieve the existing condition affecting the life and happiness of the people, and it applies to all lessees at the time the law was passed, regardless of the date of their contracts. The Court emphasized that a poor lessee does not cease to be poor because their contract predates the law, and the law's protection is mandatory and all-inclusive for lessees at the time of its passage, barring the specified exceptions. On the lessor's need to occupy: The Court ruled that the exception allowing ejectment when the lessor "has to occupy the building leased" applies only to the lessor's personal need and does not extend to the need of his sons or near relatives. The law contemplates the lessor's own need, not the needs of his dependents or relatives, as sons, whether minors or adults, should live with their father or are independent, and near relatives have no standing in the lease agreement. Furthermore, the defendant's allegation, not denied by the plaintiff, that the plaintiff has other properties he leases to others, indirectly supports the argument that the need for the premises is not absolute. On willful and deliberate non-payment: The Court found that the exceptions for subleasing without consent and willful and deliberate non-payment of rents could not be invoked in this case. The primary issue revolved around the lessor's need to occupy and the general protection afforded to lessees under the emergency legislation.
Main Doctrine
Commonwealth Act No. 66, amending Commonwealth Act No. 689, which provides protection to lessees against ejectment, applies to pending cases and can be given retroactive effect as an emergency measure enacted under the police power of the state, provided the exceptions (willful and deliberate non-payment, subleasing without consent, or lessor's need to occupy) are not met. The lessor's need must be personal and not for near relatives.