G.R. No. L-44377 December 15, 1982
LEONOR VILLAMIN and MANUEL A. SORTIJAS, petitioners, vs. JUAN ECHIVERRI, JR., JUDGE ABELARDO M. DAYRIT, as Judge of Branch XXXIX of the Court of First Instance of Manila and JUDGE BIENVENIDO S. SALAMANCA of Branch XIV of the City Court of Manila, respondents.

FACTS

This is an ejectment case. The City Court of Manila ordered tenant Leonor Villamin to vacate an apartment and pay back rentals to landlord Juan Echiverri, Jr. The judgment was based on her alleged delay in paying the January and February 1975 rentals, as the money orders for these were mailed on February 3 and 24, 1975, respectively. The Court of First Instance of Manila affirmed this decision on appeal. Villamin then filed a petition for certiorari with the Supreme Court, contending grave abuse of discretion.
Villamin had occupied the apartment since 1967 under a lease with no fixed term at a monthly rental of P165. In November 1974, the landlord verbally notified her of an increase to P300. When the landlord’s representative came to collect the January 1975 rental, Villamin tendered P165 in cash, but it was rejected in favor of the increased amount. Consequently, she sent the P165 rentals for January and February via postal money order. She had sought and received advice from a Malacañang unit that the proposed increase violated Presidential Decree No. 20, which prohibited such increases for rentals not exceeding P300.

ISSUE

Whether the courts committed grave abuse of discretion in ordering the ejectment of the tenant for alleged delay in rental payment.

RULING

The Supreme Court reversed the lower courts’ decisions and dismissed the ejectment complaint. The legal logic is that no valid ground for ejectment existed. The tenant was not in default. Her obligation was to pay the stipulated rental of P165. The alleged delay was not due to her fault but was a direct consequence of the landlord’s unjustified refusal to accept her valid tender of payment at the legal rate. By refusing the cash payment, the landlord effectively prevented the tenant from fulfilling her obligation on the exact due date, forcing her to resort to mailing the money orders.
The ejectment was motivated by the landlord’s desire to charge an increased rental, a purpose squarely prohibited by Presidential Decree No. 20. This decree froze rentals for dwelling units at not more than P300 and protected tenants on indefinite leases from ejectment based on the expiration of a term under the Civil Code, aiming to shield lower-income groups from exorbitant rents. The tenant’s actions were in compliance with the law and her lease contract. Therefore, the lower courts’ rulings constituted an error so grave as to amount to a lack or excess of jurisdiction, warranting reversal by certiorari.