GR 155553; (August, 2008) (Digest)
G.R. No. 155553 ; August 26, 2008
NIMFA MITRE REYES, ET AL., petitioners, vs. HEIRS OF EUDOSIA D. DAEZ, respondents.
FACTS
The respondents, heirs of Eudosia D. Daez, filed an ejectment case against the petitioners, who were tenants on a month-to-month basis of an apartment building in Caloocan City. The respondents alleged that a 1996 inspection by the City Engineer’s Office found the buildings old and dilapidated, recommending immediate restructuring or general repair to avoid hazards. Pursuant to a subsequent letter from the City Engineer requiring compliance, the respondents sent the petitioners notices to vacate to undertake the necessary repairs. The petitioners refused to leave.
The petitioners, in their defense, argued they were bona fide tenants for many years, covered by the Rent Control Law (B.P. 877). They contended the buildings were in sound condition due to their own maintenance and that the City Engineer’s report only indicated superficial damage and recommended general repairs, not condemnation. They asserted the repairs could be done without ejecting them and suggested the ejectment suit was a pretext to evict them and convert the property.
ISSUE
Whether the respondents have a valid ground for ejectment under Section 5(e) of B.P. 877, which allows ejectment if the lessor needs to make necessary repairs which are the subject of an existing order of condemnation by proper authorities to make the premises safe and habitable.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions ordering the petitioners’ ejectment. The legal logic rests on the application of Section 5(e) of B.P. 877. The Court found the element of an “order of condemnation by proper authorities” was satisfied. The City Engineer’s inspection report, which recommended immediate restructuring or general repair to avoid accident and hazard, coupled with the subsequent official letter from the City Engineer’s Office directing the respondents to comply with that recommendation, constituted the requisite order from a proper authority. This official directive created an obligation on the part of the lessor to make the premises safe.
The Court rejected the petitioners’ argument that the repairs could be undertaken without vacating the premises. It emphasized that the determination of the necessity for the tenants to vacate to effect the required repairs is a finding of fact best left to the trial court, which had found the need for vacation to be necessary. The petitioners failed to substantiate any grave abuse of discretion in this factual finding. Furthermore, the respondents’ motive for the ejectment was deemed irrelevant, as the law provides a specific ground for ejectment which was sufficiently proven. The bona fide need of the lessor to comply with a lawful order from public authorities for safety repairs constitutes a valid and compelling ground for ejectment under the Rent Control Law.