G.R. No. 76851 and G.R. No. 78431 , March 19, 1990
AURORA PASCUA, petitioner, vs. COURT OF APPEALS, et al., respondents. and Sps. EDUARDO D. CAÑARES and LORETA E. CAÑARES, petitioners, vs. COURT OF APPEALS and Sps. ERLINDA ASTROLOGIO and NOLI ASTROLOGIO, respondents.

FACTS

The spouses Eduardo and Loreta Cañares owned a two-door apartment building in Manila, leased to Aurora Pascua and the spouses Noli and Erlinda Astrologio. The Cañareses themselves had been renting another apartment for twenty years. In 1984, their own landlord demanded they vacate their rented home. Consequently, the Cañareses sent demand letters to their lessees, Pascua and the Astrologios, stating their need to occupy their own property and giving them time to vacate. The lessees refused.
The Cañareses filed ejectment complaints in the Metropolitan Trial Court (MTC). The MTC ruled in favor of the Cañareses in both cases. The Regional Trial Court (RTC) affirmed these decisions. On appeal, the Court of Appeals issued divergent rulings: it dismissed Pascua’s petition but ruled in favor of the Astrologios. The appellate court held that the Cañareses failed to allege and prove they did not own any other available residential unit in Manila, a requirement under the applicable rental law.

ISSUE

The primary legal issues were: (1) Whether the Cañareses’ failure to explicitly allege in their complaint that they owned no other available residential unit in Manila was fatal to their cause of action; and (2) Whether the lessees could be ejected under Article 1673 of the Civil Code, notwithstanding the provisions of Batas Pambansa Blg. 25 (as amended by B.P. Blg. 877), which governed ejectment grounds.

RULING

The Supreme Court consolidated the cases and ruled in favor of the landlord-spouses Cañareses against the Astrologios, but upheld the dismissal against Pascua due to a separate procedural failure in her case regarding rental demands. On the first issue, the Court held that while the complaint initially lacked the specific allegation, this formal deficiency was cured. The demand letter attached to the complaint as an annex explicitly stated the Cañareses’ need to occupy the property as they had no other house and were being ejected from their rented home. More importantly, the Astrologios never raised this specific objection in their answer or during the trial; they raised it for the first time only on appeal to the Supreme Court. The Court emphasized that procedural rules should not be strictly applied at the expense of substantial justice, and evidence admitted without objection can cure pleading defects.
On the second issue, the Court rejected the lessees’ argument that Article 1673 of the Civil Code was suspended by B.P. Blg. 25 for indefinite leases. It reiterated established doctrine that a lessor can recover possession of a residential unit for personal use under the conditions specified in the law. The Court found the Cañareses complied with these conditions: they needed the premises for their own use as they were being ejected from their rented home, and they had no other available property in Manila (their other property was occupied by a tenant with a lease until 1989). Therefore, the legal requirements for ejectment were satisfied. The Court acknowledged the hardship on the lessees but affirmed that the law, when correctly applied, must be upheld to ensure fairness to all parties.