Facts:

This case, G.R. No. L-24664, involves fourteen plaintiffs-appellants, namely Corazon Alegre and others, against defendant-appellee Victorina G. de Laperal. The event commenced in the Court of First Instance of Manila where the plaintiffs occupied various distinct and separate apartments owned by the defendant from around the year 1964, approximately three years prior to the case's filing. On October 27, 1964, the defendant issued a notice to the plaintiffs, informing them of a proposed rental increase set to take effect on January 1, 1965. The plaintiffs were dissatisfied with this increase and did not either agree to the new rates or vacate the properties. Instead, on January 5, 1965, they opted for a judicial consignment of the old rental amounts, filing a complaint to compel the defendant to accept these payments, seeking both a judgment on the duration of their lease and damages. In her response, the defendant asserted that the lease was on a month-to-month basis with th

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Facts:

Parties and Background

• The case involves fourteen plaintiffs (of the original eighteen) who were tenants occupying separate apartments owned by defendant Victorina G. de Laperal.
• The defendant owned several apartment houses located at the corner of Vision Street and Dimasalang Street/Aurora Boulevard in Manila.

Timeline and Transactional History

• Prior to 1964, the plaintiffs had occupied the defendant’s apartments for about three (3) years under an arrangement that was treated as a month-to-month lease.
• On October 27, 1964, the defendant served notices to the plaintiffs indicating that, effective January 1, 1965, they must pay an increased rental rate. The notice further specified that if the plaintiffs did not agree to pay the increased rate, they should vacate the premises.
• The plaintiffs, unwilling to accept the increased rentals and unwilling to vacate, instead judicially consigned an amount reflecting the old rental rate on January 5, 1965, and commenced an action before the Court of First Instance (CFI) in Manila.

Pleadings and Relief Sought

• The plaintiffs prayed that:
• The defendant be ordered to accept the old rental rates;
• The period of the lease contracts be fixed (extended) in favor of the lessees; and
• The defendant be directed to pay damages for the alleged wrongful actions.
• In her answer, the defendant maintained that:
• The lease with the plaintiffs was a month-to-month contract;
• She was entitled to increase the rentals at the expiration of each month; and
• If the plaintiffs were unwilling to pay such increases, then they should vacate the premises.

Lower Court Proceedings and Post-Judgment Actions

• On April 30, 1965, the lower court rendered judgment dismissing the plaintiffs’ complaint.
• The judgment also ordered the plaintiffs to:
• Vacate the premises they occupied;
• Pay back rentals at the old rate for up to thirty (30) days from notice of the judgment; and
• Subsequently pay the increased rentals until the apartments were vacated, inclusive of costs.
• Plaintiffs signaled their intention to appeal by giving notice on May 7, 1965, subsequently amending the notice on May 24, 1965.
• Prior to definitive appellate record approval, on May 29, 1965, the defendant moved for the execution of the judgment on the ground that the plaintiffs had failed to deposit the monthly rentals as mandated.
• Open court proceedings led to an agreement granting the plaintiffs until June 14, 1965 to deposit the rentals. When this deposit ultimately was not made, the lower court authorized the execution of its judgment on June 26, 1965.
• On June 30, 1965, the plaintiffs filed a motion for a writ of preliminary injunction before the Supreme Court to halt the execution of the judgment, which was denied.

Subsequent Arguments and Contentions

• The plaintiffs raised several issues in their briefs, including:
• The contention that the lease was not for a fixed term and thus, by law, should not be deemed a definite, month-to-month lease. They argued this under Article 1687 of the Civil Code, asserting that they were entitled to a longer lease period given their occupancy of over one year.
• Alleging that the lower court erred by failing to take judicial notice of Manila’s Ordinance No. 4841, Series of 1963, and by not holding that the increased rental rates exceeded the limits fixed by the ordinance.
• Objecting to both the dismissal of their complaint and the order authorizing the execution of the judgment during the pendency of the appeal.
• The defendant countered by emphasizing that:
• The lease was indeed for a month-to-month period, which inherently permits rental increases at the end of each month unless the tenants agree otherwise.
• The counterclaim alleged that the plaintiffs, after the expiration of their lease term, were unlawfully withholding possession of the premises, thereby invoking elements of an unlawful detainer case.

Issue:

Nature of the Lease Contract

• Is the lease, being on a month-to-month basis, automatically construed as a non-fixed, indefinite contract entitling the plaintiffs to demand a longer term?
• Does Article 1687 of the Civil Code guarantee the tenants a positive right to secure an extended term after the lease has expired, in light of their long-term occupancy?

Applicability of the City Ordinance

• Should the lower court have taken judicial notice of Ordinance No. 4841, Series of 1963, regarding the permissible limits on rental increases?
• Is there sufficient evidence on record to determine that the increased rentals exceed the statutory cap established by the ordinance?

Validity of the Lower Court’s Decision

• Was there error in the lower court’s dismissal of the plaintiffs’ complaint?
• Was it proper to order the execution of the decision during the pendency of the appeal based on the plaintiff’s failure to deposit the stipulated monthly rentals?

Jurisdiction and Nature of Execution Order

• Can the execution of the judgment, ordered before the final resolution of the appeal, be sustained under Section 10 of Rule 70 of the Rules of Court?
• How does the presence of the defendant’s counterclaim on unlawful detainer affect the appropriateness of the execution order?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)