Case Digest (G.R. No. L-57321)
Facts:
- Petitioners: Remedios Caburnay and her privies.
- Respondent: Carmen Vda. de Ongsiako.
- Location: Room 304, Raon corner Ronquillo streets, Quiapo, Manila.
- Lease Start Date: May 15, 1965.
- Initial Monthly Rental: P150.00.
- Initial Use: Office purposes, later converted to a residential unit by Caburnay.
- January 1973: Ongsiako demanded an increased rental of P200.00 per month.
- Caburnay's Refusal: Cited Presidential Decree No. 20 (Rental Law) prohibiting rent increases for residential units with monthly rentals not exceeding P300.00.
- Ejection Case: Filed by Ongsiako for non-payment of increased rentals.
- Lower Court Rulings: City Court of Manila and Court of First Instance (CFI) of Manila ruled in favor of Ongsiako.
- Supreme Court: Caburnay petitioned for a review.
Issue:
- (Unlock)
Ruling:
- 1. The Supreme Court ruled that the room occupied by Caburnay is indeed a dwelling unit under Presidential Decree No. 20.
- 2. The Supreme Court set aside the decision of the lower courts, thereby ruling tha...(Unlock)
Ratio:
- The Supreme Court's decision: Based on the finding that the premises were used for residential purposes.
- Ocular Inspection: Revealed the presence of residential amenities such as a kitchen, toilet, and bath.
- Principle: The use of the premises, not their location, determines the applicability of Presidential Decree No. 20.
- Precedent: Saure vs. Pentecostes, where residential use in a commercial area falls under the protection of the Rental Law.
- Conclusion: The lower courts erred in classifying the premises as commercial and in allowing the rent increase....continue reading
Case Digest (G.R. No. L-57321)
Facts:
In the case of Caburnay v. Vda. de Ongsiako, the petitioners, Remedios Caburnay and her privies, were tenants of Room 304 in a building owned by Carmen Vda. de Ongsiako, located at Raon corner Ronquillo streets, Quiapo, Manila. The lease began on May 15, 1965, with a monthly rental of P150.00. Initially, the room was intended for office purposes but was later converted into a residential unit by Caburnay. In January 1973, Ongsiako demanded an increased rental of P200.00 per month, which Caburnay refused to pay, citing Presidential Decree No. 20 (Rental Law) that prohibited such an increase for residential units with monthly rentals not exceeding P300.00. Consequently, Ongsiako filed an ejection case against Caburnay for non-payment of rentals. The City Court of Manila ruled in favor of Ongsiako, ordering Caburnay to vacate the premises and pay the increased rental. The Court of First Instance (CFI) of Manila affirmed this decision. Caburnay then petitioned for a review by the Supreme Court.