G.R. No. L-24664 - Alegre vs. De Laperal

The law does not grant lessees a positive right to demand a longer lease term, even if the contracts are not for a fixed period.
Article 1687 of the Civil Code allows the court to "fix a longer term" at its discretion.
Tenants must seek an extension before the lease termination, not after.
In this case, the action was initiated after the lease had expired, negating the possibility of extending the term.

The plaintiffs cited a city ordinance that limits rental increases to 10% per annum based on the assessed value of the property.
The court found no competent evidence regarding the assessed value of the building and land.
Without this evidence, the court could not determine if the rental increases exceeded the ordinance's limit.
The plaintiffs' argument regarding the ordinance was deemed meritless.

The plaintiffs contested the court's authority to execute the judgment during the appeal, claiming the case was for specific performance, not unlawful detainer.
The defendant's counterclaim alleged unlawful withholding of possession by the plaintiffs after the lease's expiration.
All elements of an unlawful detainer case were present in the defendant's counterclaim.
The counterclaim was verified, indicating the defendant's intent to treat it as a complaint for unlawful detainer.

Regardless of the nature of the counterclaim, the lower court had the authority to execute its decision under Rule 39, Section 2 of the Rules of Court.
The defendant's motion for execution was filed before the plaintiffs' record on appeal was approved, maintaining the court's jurisdiction.
The approval of the record was provisional and did not preclude the court from addressing the motion for execution.

The defendant's counterclaim was necessary and related to the transaction at issue, making it compulsory.
Had the d...continue reading