G.R. No. L-1560 - Estrada vs. Caseda

Demetria Estrada, the plaintiff and appellant, initiated an action for unlawful detainer against defendant Uldarico Caseda.
The dispute arose from a lease agreement where the defendant occupied a part of a dwelling rented for P26 per month.

On September 5, 1945, the plaintiff filed her suit alleging that the defendant was unlawfully retaining possession of the leased premises.
On August 11, 1945, the plaintiff, needing the property for her married daughter to reside, formally notified the defendant in writing to vacate the premises by the first of the following month, a notice which the defendant disregarded.

The municipal court, presided over by Judge Mariano Nable, rendered a judgment on October 13, 1945, in favor of the plaintiff, ordering the defendant to leave the premises and to pay rent from October 1, 1945, at the agreed rate of P26 per month.
On appeal, the defendant argued via an answer that the true motive of the suit was the plaintiff’s intention to evict him in order to lease the premises to third parties at a higher, black market rental rate.

The Court of First Instance of Manila, with Judge Rafael Dinglasan presiding, reversed the municipal court decision.

The reversal was largely based on the interpretation of Commonwealth Act No. 689 (as amended) which provides only the following grounds for ejecting a lessee or occupant of a dwelling:

ii. Necessity for the lessor to occupy the building; iii. Unauthorized subleasing of the premises.

The court found that the plaintiff’s need for the premises for her married daughter did not fall under the statutory ground of personal necessity for occupancy by the lessor.

Commonwealth Act No. 689 was approved on October 15, 1945, and originally provided a period of two years during which its provisions would be in force.
Republic Act No. 66, approved on October 18, 1946, amended Section 14 of the Act extending its period of effect to four years after the original approval date.
The legal issue arose as to when this four-year period commenced and whether the existing lease was still within this period.
The Court noted the established rule that an amended act is construed as if it had been originally enacted in its amended form for actions after its adoption and does not have retroactive effect to alter contractual relations already in existence.
Consequently, the period for the act’s validity was computed from October 15, 1945, and expired on October 15, 1949.

Whether the amendment provided by Republic Act No. 66, which extended the force of Commonwealth Act No. 689, could be applied retroactively to affect the cause of action that arose before the enactment of the amendment.

Whether the plaintiff’s claim based on the need for her married daughter to occupy the premises falls within the statutory grounds for ejecting a lessee, given that the prescribed grounds under the amended act are limited to:

Whether the judgment of the Court of First Instance, which reversed the municipal court decision for not finding any statutory basis for eviction under Commonwealth Act No. 689, was in accordance with law and statutory interpretation.