Title
Alegre vs. De Laperal
Case
G.R. No. L-24664
Decision Date
May 29, 1968
The Supreme Court upheld the dismissal of tenants' complaint against increased rental rates and lease duration, permitting judgment execution during the appeal.
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Case Digest (G.R. No. L-24664)

Facts:

  • The case involves Corazon Alegre and thirteen other plaintiffs (plaintiffs-appellants) against Victorina G. de Laperal (defendant-appellee).
  • The dispute centers on a landlord-tenant relationship regarding several apartment units owned by the defendant in Manila.
  • The plaintiffs had been tenants for approximately three years before the dispute.
  • On October 27, 1964, the defendant notified the plaintiffs of an increase in rental rates effective January 1, 1965.
  • The plaintiffs refused to accept the increase or vacate the premises and judicially consigned the old rental amounts on January 5, 1965.
  • They filed a complaint in the Court of First Instance of Manila, seeking to compel the defendant to accept the old rates, fix lease duration, and award damages.
  • The defendant argued that the lease agreements were month-to-month, allowing her to increase rent monthly.
  • The lower court dismissed the plaintiffs' complaint on April 30, 1965, ordering them to vacate and pay back rentals at the old rates for thirty days.
  • The plaintiffs appealed on May 7, 1965, and amended their notice on May 24, 1965.
  • The defendant moved for execution of the judgment on May 29, 1965, citing the plaintiffs' failure to deposit required rentals.
  • The court allowed execution on June 26, 1965, despite the pending appeal, and the plaintiffs sought a writ of preliminary injunction from the Supreme Court, which was denied.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's ruling that the lease contract was for a definite period.
  • The Court ruled that the lower court did not err in failing to take judicial notice of the ordinance due to lack of competent evidence regarding the property's assessed value.
  • The dismissal of the plaintiffs...(Unlock)

Ratio:

  • The Supreme Court reasoned that the lease agreements were for a definite period, allowing the defendant to increase rent monthly.
  • The plaintiffs' claim that the lease was not fixed was unfounded; Article 1687 of the Civil Code grants discretion to fix a longer term, which the plaintiffs did not demonstrate was abused.
  • The case was initiat...continue reading

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