Case Summary (G.R. No. 107057)
Background of the Case
The petitioners, who had been lessees for approximately 25 years under a written lease agreement with Vivien B. Bernardino, continued their occupancy after the lease expired on January 31, 1988. Monthly rental payments were made despite the absence of a written lease post-expiration. On July 11, 1991, Bernardino sold the apartment building to Jovan Land, Inc. Shortly after, both Bernardino and Jovan Land, Inc. served eviction notices to the petitioners, leading to the initiation of ten unlawful detainer cases.
Judgments at Various Levels
The Metropolitan Trial Court (MeTC) rendered a joint judgment favoring the private respondent, ordering the petitioners to vacate the premises and pay various amounts for rental arrears and reasonable compensation for continued occupancy. The MeTC opined that the lease had transitioned to a month-to-month basis, and based on Articles 1670 and 1687 of the Civil Code, concluded that judicial eviction was warranted upon expiration of the lease period.
Appeal to the Regional Trial Court (RTC)
The petitioners appealed to the RTC, which reversed the MeTC's decision, stating that the cases were governed by B.P. Blg. 25 and B.P. Blg. 877. The RTC determined that these laws suspended the application of the Civil Code regarding eviction based on the expiration of a lease when the conditions outlined in the applicable laws were met. It also criticized the rental increases deemed excessive.
Court of Appeals Decision
The private respondent sought a review from the Court of Appeals, which reinstated the MeTC's ruling. The Court ruled that an oral month-to-month lease is considered to have a definite term, subject to termination by a demand to vacate from the lessor, thus validating the petition for eviction. The Court emphasized a shift in legislative language regarding the grounds for ejectment and relied on prevailing jurisprudence.
Supreme Court's Examination
The Supreme Court's review focused on the legality and justification for the increased rental rates set by the MeTC and endorsed by the Court of Appeals. It underscored that in ejectment cases, only reasonable compensation for occ
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Case Overview
- This case is a petition for review on certiorari seeking the reversal of a decision made by the Court of Appeals on September 8, 1992.
- The case originated from several ejectment cases filed against the petitioners by the private respondent, Jovan Land, Inc.
- The petitioners had been occupying a ten-door apartment building for about 25 years under a lease that expired on January 31, 1988.
Background of the Lease
- The apartment building was initially owned by Vivien B. Bernardino, with whom the petitioners had a written lease agreement.
- After the lease expired, the petitioners continued to occupy their respective units, and monthly rentals were collected without a renewed written contract.
- On July 11, 1991, the building was sold to Jovan Land, Inc., which led to demands for the petitioners to vacate their units starting on July 15, 1991.
Legal Proceedings
- Following the refusal of the petitioners to vacate, ten separate unlawful detainer cases were filed against them before the Metropolitan Trial Court (MeTC) of Manila.
- The MeTC ruled that the lease had become a month-to-month tenancy and ordered the petitioners to vacate and pay accumulated rental arrears along with reasonable compensation for the use of the premises