Case Summary (G.R. No. 171891)
Background of the Case
In her defense, Lopez refuted the claims of rental default, asserting that Umale-Cosme had failed to collect the rent as it became due, thereby creating the appearance of arrears. Lopez contended that since February 1999, she had been depositing her monthly rent in a bank in trust for Umale-Cosme. On March 19, 2003, the Metropolitan Trial Court (MeTC) ruled in favor of Umale-Cosme, mandating Lopez to vacate the premises, pay back rent, and cover attorneys' fees.
Ruling of the Regional Trial Court
Following an appeal, the Regional Trial Court (RTC) reversed the MeTC's decision. The RTC concluded that the lease agreement lacked a definite period, thus negating the grounds for ejection based on contract expiration until a period could be fixed by judicial authorities. The RTC referred to the provisions of the Rent Control Law and highlighted that the lessee could not be evicted if no definite lease period existed.
Court of Appeals Decision
Umale-Cosme subsequently appealed to the Court of Appeals (CA), which determined that Lopez’s tenancy was effectively a month-to-month lease. The CA relied on provisions of the Civil Code which assert that when a lease period is unspecified, it is deemed to continue monthly if the rent is paid monthly. Hence, the CA found that Umale-Cosme had legally terminated the lease and could seek ejectment. The CA dismissed Lopez’s claims regarding the lack of a definite lease period.
Reaffirmation of Ejectment Rights
In affirming the CA's decision, the Supreme Court reiterated that a month-to-month lease has a definite period that terminates at the end of any monthly cycle, providing grounds for ejectment if the lessee fails to pay rent. The Court emphasized that non-payment by Lopez resulted in Umale-Cosme havin
...continue readingCase Syllabus (G.R. No. 171891)
Case Overview
- The case involves a petition for review on certiorari under Rule 45, seeking to overturn the Decision and Resolution of the Court of Appeals (CA) in CA G.R. SP No. 82808.
- The petitioner, Hernania "Lani" Lopez, is the lessee of an apartment unit owned by the respondent, Gloria Umale-Cosme, located at 15 Sibuyan Street, Sta. Mesa Heights, Quezon City.
- The rental payment as of 1999 was P1,340.00 per month.
Background of the Case
- On April 19, 1999, respondent filed a complaint for unlawful detainer against petitioner, citing expiration of the lease contract and non-payment of rentals since December 1998.
- Petitioner denied defaulting on the rental payments, contending that respondent had not collected them, which was purportedly done to create the illusion of arrears.
- Petitioner claimed to have been depositing monthly rentals in a bank in trust for the respondent since February 1999.
Judgment of the Metropolitan Trial Court (MeTC)
- On March 19, 2003, the MeTC ruled in favor of the respondent, ordering the petitioner to vacate the premises, pay back rent from December 1998, and settle P20,000.00 for attorney’s fees and costs of suit.
Reversal by the Regional Trial Court (RTC)
- The RTC