G.R. No. L-36797 - Gutierrez vs. Cantada

The petitioners, Jose Gutierrez and Adelaida Gutierrez, are the lessors and owners of the land and residential house at issue.
The private respondents, Armando Cantada and Carmelita C. Cantada, are the lessees occupying the property under a lease agreement.
The case involves a petition for certiorari challenging the decision of respondent Judge Santiago O. Tanada of the Court of First Instance, Rizal, Caloocan City Branch XXXIII, which dismissed an ejectment suit initiated by the petitioners.

Republic Act No. 6359 (referred to in some sources as Republic Act No. 6539), a police power measure enacted to alleviate the plight of lessees by suspending certain ejectment actions.
Presidential Decree No. 20, which continued and expanded the suspension of ejectment actions for leases not fixed for a definite period.

Under Section 4 of Republic Act No. 6359, provisions of Article 1673 of the Civil Code (which allow judicial ejectment upon expiration of a lease period) were suspended for two years from July 14, 1971, unless the lease was for a definite term.
Timeline of proceedings:

The complaint for ejectment was filed on April 22, 1972, during the period when the suspension was in effect.
In a related case, Petitioners had filed a civil suit for ejectment (Civil Case No. 8805) on April 27, 1972, against Benjamin Leyva, later involving the respondent spouses as intervenors.
After a City Court decision on September 21, 1972 favorable to petitioners, respondent spouses appealed, and on February 14, 1973, Judge Tanada reversed the decision, dismissing the ejectment suit based on the statutory suspension.

The lease agreement was for a non-definite period and was subject to the suspension of the ejectment grounds under Article 1673.
The rental arrangement—where the respondents paid modest monthly rentals (P30.00 or P40.00) for residential use—was in line with an understood residential occupancy and did not trigger the ejectment provision.
There was no evidence of default, as the respondents had been up-to-date with their rental payments.

The lower courts observed that petitioners themselves had assured the lessees of long-term occupancy in connection with the purchase of the house, evidenced by the respondents’ affirmative admission.

The suspension of ejectment actions was a deliberate exercise of the State’s police power aimed at protecting lessees from undue loss, especially during times of economic distress.
The applicability of both Republic Act No. 6359 and the subsequently enacted Presidential Decree No. 20 extended even to existing lease contracts, reaffirming legislative intent to secure the welfare of the less privileged.
Petitioners attempted to challenge this application on constitutional grounds, arguing an impairment of contractual rights and a violation of equal protection; however, such arguments were procedurally untimely and substantively unavailing.

The petition for certiorari was ultimately dismissed by the higher court.
The Court affirmed the validity of the respondent Judge’s decision in light of the police power measures in force at the time of the action.
It was noted that a new Rent Control Law (Batas Pambansa Blg. 25) had already come into effect as of April 10, 1979, which could be availed by petitioners in the future if applicable.

Whether the filing of an ejectment suit was proper given that the lease was for an indefinite period and was subject to a statutory suspension.

The central issue was the applicability of police power legislation (Republic Act No. 6359 and Presidential Decree No. 20) that suspended the execution of ejectment actions in cases of non-definite leases.

Whether the respondents’ timely rental payments and established residential occupancy negated the petitioners’ claim for ejectment.

The evidence showed that respondents were current in their rental obligations, thereby undermining any justification for ejectment based on default or lapse of lease duration.

The constitutional question raised by petitioners regarding the equal protection clause and whether the police power measures amount to an impermissible impairment of contractual obligations.

This raised the issue of whether such remedial legislation constituted class legislation and if its application to existing contracts was constitutionally valid.

Whether the procedural posture of raising constitutional challenges at a later stage was acceptable, and if not, whether it should bar the petition.