G.R. No. L-46468 - Saure vs. Pentecostes

Petitioner Francisco Saure was a lessee occupying a unit in a building owned by the private respondents, the spouses Telesforo and Nieves Galang.
The building, although partly used for a small photography shop run by the petitioner, was primarily used as his residence for over ten years.
The dispute arose when the private respondents sought to eject the petitioner for refusing to agree to a rental increase from P50.00 to P180.00, a matter affecting leases where monthly rentals do not exceed P300.00.

The Municipal Judge of Camiling, Tarlac, respondent Judge Prudencio S. Pentecostes, ordered the ejectment of petitioner despite the absence of a fixed term for the lease.
The judge’s action disregarded the explicit command of Presidential Decree No. 20, which suspended ejectment cases in all instances except where the lease is for a definite period, and also restricted rental increases for low-income dwelling units.

The Citizens Legal Assistance Office of the Ministry of Justice intervened to nullify and set aside the ejectment decision and the subsequent denial of the petitioner’s motion for relief from judgment.
The intervention was based on the clear violation of the protective provisions of Presidential Decree No. 20.

Presidential Decree No. 20 was designed to alleviate the plight of lessees by suspending traditional ejectment proceedings for residential units with rentals not exceeding P300.00.
Previous decisions such as Salaria v. Buenviaje and Gutierrez v. Cantada established that the decree’s application is not defeated by the lessor’s personal use of the premises or by its location in a commercial district.
The definition of a residential unit in Batas Pambansa Big. 25 further reinforces that a dwelling used for residential purposes—even with a small business operation integrated therein—remains subject to the decree’s protections.

During the litigation, petitioner failed to deposit the monthly rental of P50.00 as agreed, although he had offered to pay.
Private respondents refused the offered payment, leading to a matter requiring that petitioner be ordered to pay back rentals while ensuring no injustice to either party.

Whether respondent Judge Pentecostes had jurisdiction to order the ejectment of the petitioner despite the pending protective provisions of Presidential Decree No. 20.
Whether the use of the premises (with a small photography shop as a supplementary business) altered its classification from a residential unit to a commercial establishment, thereby affecting the applicability of the decree.
Whether the location of the building in a commercial district is a sufficient basis to exclude it from the protective ambit of the decree designed for residential dwelling use.
Whether the petitioner’s failure to deposit the agreed rental during litigation affects the merits of his case regarding the jurisdictional infirmity caused by the ejectment proceedings.
How the rulings in Salaria v. Buenviaje and Gutierrez v. Cantada influence the application of Presidential Decree No. 20 to the present case.