G.R. No. 134267. May 9, 2005.
DAVID G. DULA, petitioner, vs. DR. RESTITUTO MARAVILLA and TERESITA MARAVILLA, respondents.

FACTS

Respondents-spouses Maravilla purchased an apartment building in Makati City in November 1993. Petitioner David Dula had been occupying Unit A as a lessee since 1968 under an oral month-to-month lease at a monthly rental of P2,112.00. On January 10, 1994, respondents sent petitioner a notice terminating his lease effective January 31, 1994, citing their need for personal use and giving him three months to vacate. Petitioner refused to leave.
Consequently, respondents filed an ejectment complaint against petitioner before the Metropolitan Trial Court (MeTC) of Makati. The MeTC ruled in favor of the respondents, ordering petitioner to vacate and pay accrued rentals. This decision was affirmed in toto by the Regional Trial Court (RTC) on appeal. The Court of Appeals subsequently affirmed the RTC decision but deleted the award of attorney’s fees.

ISSUE

Whether the MeTC correctly ordered the ejectment of the petitioner based on the grounds alleged in the complaint.

RULING

The Supreme Court denied the petition and affirmed the assailed Court of Appeals decision. The Court held that the complaint sufficiently stated a cause of action for ejectment under Batas Pambansa Blg. 877. The pleading alleged two statutory grounds: the owner’s legitimate need to repossess the property for personal use under Section 5(c), and the expiration of the lease period under Section 5(f). The Court clarified that while the complaint’s allegation for personal use did not explicitly state the respondents owned no other available residential unit in the same city, this did not render the complaint fatally defective. Such an omission pertains to the adequacy of evidence during trial, not to the sufficiency of the cause of action stated in the pleading.
On the second ground, the Court ruled that the expiration of the lease was a valid basis for ejectment. Petitioner’s month-to-month lease, terminable at the end of every month, was deemed expired upon the service of the notice to vacate. The Court explained that Article 1687 of the Civil Code, which allows courts to fix a longer term for leases with no fixed period, was suspended by Section 6 of B.P. Blg. 877. Therefore, the lessor could terminate the lease upon the expiration of any 30-day period by serving a notice to vacate. The respondents’ January 1994 notice effectively terminated the lease, making petitioner’s continued possession unlawful from the expiry of the notice period. The prolonged litigation, spanning over ten years, was deemed to have extended petitioner’s occupancy sufficiently, warranting the immediate execution of the judgment.