G.R. No. 3402
JOSE ITURRALDE v. FRANCISCA ALFONSO

FACTS
The plaintiff, owner of a parcel of land in the hacienda “La Estanzuela,” sued the defendant for possession and rent. The defendant had occupied the 20,400 sq m. land paying ₱2 per annum until May 1902. She refused the ₱2 for the year 19021903 and contested the landlord’s notice that, effective May 1903, the rent would be increased to ₱50 per annum. The justice of the peace ruled for the defendant; the plaintiff appealed. The Court of First Instance found that the defendant was a tenant, that she had agreed to pay ₱2 for the year beginning May 1902, and that the new rent of ₱50 per annum was proper for subsequent years. It ordered payment of the ₱2 arrear, ₱50 per annum thereafter, delivery of possession to the plaintiff, and costs. The defendant appealed to the Supreme Court.

ISSUE
Whether the landowner may lawfully increase the rent after the expiration of the tenant’s yearly term, and whether the plaintiff is entitled to recover the unpaid ₱2, the subsequent ₱50 annual rent, possession of the land, and costs.

RULING
The Supreme Court affirmed the lower court. It held that a landowner may fix a new rental value for a succeeding period; such a fixation does not bind the tenant for the term already agreed but may be imposed on renewal. The tenant may accept the increase, vacate, or, if he remains in possession, must pay a reasonable rent as determined by the court. Here, the evidence showed the tenant had agreed to the ₱2 rent for 1902‑1903 and that the ₱50 rent for periods commencing May 1903 was justified. Consequently, the plaintiff is entitled to: (a) ₱2 for the year of May 1902‑1903; (b) ₱50 per annum for each subsequent year until possession is delivered; (c) delivery of possession of the land; and (d) costs. Judgment was entered accordingly and the record remanded for execution.