G.R. No. L-1811 - Balveran vs. Court of Appeals

On June 26, 1945, the respondents, Teofila Zaballero Vda. de Unson and Amando Zaballero, initiated an action in the justice of the peace court of Lucena, Tayabas, seeking to eject the petitioners, Gregorio Balveran and Mercedes Cabana, from the western part of a house located at the corner of Zamora and Gardiner Streets.

The respondents claimed that they needed the portion of the house to establish a store, contending an economic motive that also impelled them to subsequently lease the property at a higher rental rate to a third party (specifically a Chinaman).

The petitioners defended their occupancy by asserting that they were lawful lessees of the premises, paying a monthly rental of P75.

They further argued that the real purpose of the respondents’ action was to dislodge them in order to benefit from a higher rental arrangement, thus exposing an ulterior motive in the ejectment suit.

After trial, the justice of the peace court rendered judgment in favor of the respondents and against the petitioners.

The Court of First Instance, after its own trial, confirmed the decision in favor of the respondents.

The judgment from this court not only ordered the petitioners to vacate the premises but also required them to pay a monthly rental of P75 starting from May 15, 1945, and an additional sum of P100 as attorney’s fees, along with the costs.

Dissatisfied with the Court of First Instance’s ruling on certain aspects, the petitioners appealed to the Court of Appeals.

The Court of Appeals largely affirmed the earlier decision except for modifying the portion pertaining to the payment of attorney’s fees.

The petitioners elevated the case to the Supreme Court via a certiorari petition.

Their principal contention was that the intended use of the premises by the respondents (for opening a store) was not a valid ground for ejectment under the Rental Law (Commonwealth Act No. 689, as amended by Republic Act No. 66).

They also argued that even though the premises were utilized both as a dwelling and a place of business (hence supposedly protected under Section 1 of the Rental Law for home industries), such protection should have precluded the ejectment action.

The petitioners invoked the protective measure under Section 1 of Commonwealth Act No. 689, which deems a building used both as the dwelling and place of business for home industries as included within its provisions.

However, it was noted that the period during which the Rental Law provided these protections had expired on October 15, 1949, as established in the case of Estrada vs. Caseda (G.R. No. L-1560, decided on October 25, 1949).

Whether the intended use of the premises by the respondents—to open a store—is a ground for ejectment under the provisions of the Rental Law (Commonwealth Act No. 689, as amended by Republic Act No. 66).
Whether the petitioners’ lease, which allowed for the premises to be used both as a dwelling and as a place of business (in accordance with Section 1 of the Rental Law), should have protected them from the ejectment action.
The relevance and applicability of the Rental Law’s protection period, especially considering that the statute’s effective period expired on October 15, 1949, thereby potentially nullifying the petitioners' defense.