Title
Acasio vs. Corporacion de los PP. Dominicos de Filipinas
Case
G.R. No. L-9428
Decision Date
Dec 21, 1956
Sub-lessee Domingo Acasio refused to pay increased rent, claiming lease rights under Article 1687 of the Civil Code. Courts ruled he was not the direct lessee, affirmed the rent hike as reasonable, and ordered eviction for failing to pay.
Font Size:

Case Digest (G.R. No. L-9428)

Facts:

  1. Ownership and Lease of the Property:
    The plaintiff, Corporacion de los PP. Dominicos de Filipinas, owned a house located at No. 651-A Invernes, Sta. Ana, Manila. The property was leased to Esteban Garcia for a monthly rent of P75. Garcia sub-leased two rooms in the house to Domingo R. Acasio and his wife, Vicenta Tengco Acasio, who paid a monthly rent of P25.

  2. Notice to Vacate and Legal Action:
    In 1950, Esteban Garcia notified the Acasio spouses to vacate the premises. When they refused, Garcia filed an action for illegal detainer against them (Civil Case No. 11813). The Court of First Instance of Manila dismissed the complaint on January 9, 1952, due to equitable circumstances.

  3. New Lease Agreement:
    After Garcia vacated the premises in January 1952, Mrs. Acasio approached the Bank of the Philippine Islands (BPI), which administered the plaintiff's properties, to request a lease of the house. She was informed that the rent would increase to P100. Despite her reluctance, she paid the increased rent for February 1952.

  4. Protest and Refusal to Pay Increased Rent:
    On the same day, Domingo Acasio wrote a letter to the BPI President protesting the rent increase. The BPI responded on February 19, 1952, stating that the increase was justified due to the property's increased assessed value and improvements. The Acasios refused to pay the increased rent, leading to the filing of an ejectment case against Domingo Acasio on September 18, 1952.

  5. Court of First Instance Decision:
    The Court of First Instance ruled that Acasio could continue occupying the premises until July 31, 1953, at a monthly rent of P75. After that date, he was required to pay P100 monthly or vacate the premises.

  6. Court of Appeals Decision:
    The Court of Appeals reversed the lower court's decision, holding that Acasio's refusal to pay the increased rent violated the lease terms. It ordered Acasio to vacate the premises and pay P100 monthly from March 1, 1952.

  7. Acasio's Claim as Lessee:
    Acasio claimed that he had been the lessee since the Japanese occupation and argued that he was entitled to the benefits of Article 1687 of the New Civil Code, which allows courts to fix a longer lease term for lessees who have occupied the premises for over a year.

  8. Findings on Lessee Status:
    The Court of Appeals found that Acasio was not the lessee but a sub-lessee under Esteban Garcia from 1945 to 1952. The court also noted that Mrs. Acasio's payment of the increased rent in February 1952 constituted a new lease agreement, not a renewal of a previous lease.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Lessee vs. Sub-Lessee:
    Article 1687 of the New Civil Code applies only to lessees who have a direct contractual relationship with the property owner. Acasio, as a sub-lessee, did not have such a relationship and therefore could not invoke the benefits of the article.

  2. Formation of a New Lease Agreement:
    Mrs. Acasio's payment of the increased rent, despite her reluctance, constituted a new lease agreement. Reluctance does not negate consent in the formation of a contract, as long as the act is voluntary and not coerced.

  3. Reasonableness of Rent Increase:
    The increase in rent was justified by the property's increased assessed value, improvements, and the economic conditions at the time. The courts have discretion to determine the reasonableness of rent increases based on the circumstances of each case.

  4. Non-Retroactivity of the New Civil Code:
    Even if Acasio had been the lessee before the enactment of the New Civil Code, he could not claim the benefits of Article 1687 retroactively. Articles 2252 and 2255 of the New Civil Code provide that new provisions affecting vested rights do not have retroactive effect.

  5. Discretion of Courts in Fixing Lease Terms:
    The power of courts to fix a longer lease term under Article 1687 is discretionary and must be exercised based on the equities of the case. In this case, no equities justified extending the lease term for Acasio.

The Supreme Court concluded that the Court of Appeals did not err in its decision and affirmed the ruling with costs against Acasio.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.