Case Summary (G.R. No. 159507)
Summary of Proceedings
The respondent initiated the unlawful detainer action in the City Court of Manila, claiming the petitioners were behind on rent and that she needed the apartment for repairs and personal use. The petitioners acknowledged their tenancy but cited complications regarding rental collections due to the respondent's unavailability. The City Court found in favor of the respondent, ordering the petitioners to vacate the premises and pay outstanding rent along with attorney's fees. This judgment was affirmed by the Court of First Instance, which the petitioners subsequently appealed to the Court of Appeals, but their petitions were dismissed for lack of merit.
Grounds of Appeal
In their review petition, the Santos couple cited several arguments against the appellate court's ruling. They contended that there was no delinquency in rent, as they had attempted payment that went unreceived due to the respondent’s absence. They also argued that the notice to vacate was not delivered properly, rendering the eviction invalid. Furthermore, they claimed a right of first refusal to buy the apartment per Presidential Decree No. 1517 after being tenants for 28 years. They maintained that the respondent did not demonstrate sufficient need for the premises, and the court’s reliance on previous rulings was flawed.
Court's Findings on Lease Agreement
The Supreme Court emphasized that the petitioners, through their counterclaim, admitted to being legitimate tenants under a month-to-month lease agreement, effectively establishing a definite rental period. Referencing the case of Rantael vs. Court of Appeals, the Court concluded that the nature of a month-to-month lease allowed either party to terminate the lease with proper notice, supporting the respondent's right to eject the petitioners.
Judicial Ejectment Justifications
The Court ruled that judicial ejectment is permissible under Article 1673 of the Civil Code if the lease agreement has either expired or if the grounds for ejectment are met, including non-payment of rents, which was established in this case. The Court noted that despite the petitioners’ claims, there was evidence of their delinquency in rent payments as determined by the lower courts.
Additional Legal Considerations
The Court addressed the petitioners' claims regarding the preferential right to purchase under Presidential Decree No. 1517, asserting that any such right only applies when the tenant has built their own residenc
...continue readingCase Syllabus (G.R. No. 159507)
Case Background
- The case involves an appeal by certiorari from the decision of the Court of Appeals, which affirmed the judgment of the Court of First Instance of Manila regarding an unlawful detainer case.
- Private respondent Aurora Gutierrez filed the unlawful detainer action against petitioners Arturo P. Santos and Adelina Y. Santos, citing personal use of the premises and the need for repairs, as well as the alleged delinquency in rental payments by the petitioners.
Parties Involved
- Petitioners: Arturo P. Santos and Adelina Y. Santos, who claim to be legitimate tenants of the apartment.
- Respondent: Aurora Gutierrez, the owner of the apartment, seeking to evict the petitioners.
Legal Proceedings
- The City Court ruled in favor of Gutierrez, ordering the Santos couple to vacate the premises and pay overdue rent along with attorney's fees.
- The petitioners appealed to the Court of First Instance, which upheld the City Court's decision, finding it consistent with the evidence and applicable law.
- The petitioners subsequently sought a review from the Court of Appeals, which dismissed their petition, affirming the lower court's ruling.
Claims by Petitioners
- The petitioners contended they were never delinquent in rent payments, arguing that their rental payments were deposited in the bank when the collector could not be located.
- They argued that the notice to vacate sent by registered mail did not constitute suffici