Title
Alegre vs. De Laperal
Case
G.R. No. L-24664
Decision Date
May 29, 1968
Tenants challenged a landlord's rental increase, claiming lease duration and damages; court ruled for landlord, affirming month-to-month leases and execution during appeal.
Font Size:

Case Digest (G.R. No. L-24664)

Facts:

  1. Parties Involved:

    • Plaintiffs: Corazon Alegre, Marciano Bao, Rafael Adelan, Salud Lualhati, Elena Morales, Pedro Marcelo, William Sanosa, Milagros Santiago, Violeta Tan, Tomas Ignacio, Mariano Sy, Paulino Francisco, Bernabe Lopez, James Tan, and Clara Bataller.
    • Defendant: Victorina G. de Laperal, owner of apartment houses located at Vision Street corner Dimasalang Street and Aurora Boulevard, Manila.
  2. Background of the Case:

    • Plaintiffs were tenants in defendant’s apartment houses for about three years prior to 1964.
    • On October 27, 1964, defendant notified plaintiffs of increased rentals effective January 1, 1965, and demanded that they either pay the new rates or vacate the premises.
    • Plaintiffs refused to pay the increased rentals or vacate. Instead, on January 5, 1965, they judicially consigned the old rental amounts and filed a complaint in the Court of First Instance of Manila.
  3. Plaintiffs’ Claims:

    • Plaintiffs sought to compel defendant to accept rentals at the old rates.
    • They requested the court to fix the duration of the lease contracts.
    • They also prayed for damages.
  4. Defendant’s Defense:

    • Defendant argued that the lease contracts were on a month-to-month basis, allowing her to increase rentals at the end of each month.
    • She contended that plaintiffs must either pay the increased rates or vacate the premises.
  5. Lower Court Decision:

    • On April 30, 1965, the lower court dismissed plaintiffs’ complaint.
    • It ordered plaintiffs to vacate the premises and pay back rentals at the old rates up to 30 days from notice of judgment, and thereafter at the increased rates until vacating.
  6. Execution of Judgment:

    • Plaintiffs appealed to the Supreme Court but failed to deposit the required rentals.
    • The lower court authorized execution of the judgment during the pendency of the appeal.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Lease Contracts:

    • The lease contracts were on a month-to-month basis, allowing the lessor to increase rentals at the end of each month. Article 1687 of the Civil Code does not grant lessees the right to demand a longer lease term; it merely gives courts discretion to fix a longer term.
  2. Manila Ordinance No. 4841:

    • The ordinance limits rental increases to 10% per annum of the assessed value of the property. However, without evidence of the assessed value, the court could not determine if the increased rentals violated the ordinance.
  3. Execution of Judgment:

    • The lower court had authority to order execution under Section 10 of Rule 70 of the Rules of Court, as the case involved unlawful detainer elements. Even if treated as an ordinary action, execution was proper under Rule 39, Section 2, since the motion for execution was filed before the approval of the record on appeal.


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.