G.R. No. L-36797 May 3, 1979
JOSE GUTIERREZ and ADELAIDA GUTIERREZ, petitioners, vs. ARMANDO CANTADA, CARMELITA C. CANTADA, HON. SANTIAGO O. TAÑADA, Presiding Judge, Court of First Instance, Rizal Branch XXXIII, Caloocan City, respondents.

FACTS

Petitioners Jose and Adelaida Gutierrez filed an ejectment suit in the City Court of Caloocan City on April 27, 1972, against Benjamin Leyva, concerning a parcel of land. Private respondents Armando and Carmelita Cantada, who had purchased a house standing on that land from Leyva, intervened in the suit. They admitted petitioners’ ownership but asserted they had spent their life savings on the house based on an assurance from petitioners that they could remain for a substantial number of years. The City Court ruled in favor of the Gutierrezes and ordered ejectment. The Cantadas appealed to the Court of First Instance (CFI).
Respondent Judge Santiago O. Tañada of the CFI reversed the lower court and dismissed the ejectment complaint. The CFI found the lease was for residential purposes with a monthly rental of P30.00 or P40.00, and that no definite period for the lease had been agreed upon. The court held the Cantadas were current in their rental payments and that the only apparent ground for ejectment was the expiration of the period fixed under Article 1687 of the Civil Code, which provides for a month-to-month lease in the absence of a specified term.

ISSUE

Whether the respondent Judge committed a grave abuse of discretion in dismissing the ejectment suit based on the applicable rental control laws.

RULING

The Supreme Court dismissed the petition, upholding the CFI decision. The ruling was anchored on police power legislation designed to protect lessees. When the ejectment suit was filed on April 27, 1972, Republic Act No. 6359 was in effect. This law suspended, for two years from July 14, 1971, the application of Article 1673(1) of the Civil Code (which allows ejectment upon expiration of the lease period) for dwelling units where the lease was not for a definite period. Since the CFI found the lease here was without a definite term, the filing of the suit within the two-year suspension period was prohibited.
Subsequently, Presidential Decree No. 20, which received constitutional sanction as part of “the law of the land,” extended this suspension indefinitely. The CFI’s decision, rendered in 1973, correctly considered this subsequent decree. The Supreme Court emphasized that such rental control laws are a valid exercise of police power to address social and economic imbalances, as established in precedents like Pangasinan Transportation Co. v. Public Service Commission. Petitioners’ belated challenge to the constitutionality of these laws was procedurally infirm, as constitutional questions must be raised at the earliest opportunity. The Court found no grave abuse of discretion, as the respondent Judge’s application of the prevailing protective legislation was legally sound.