G.R. No. L-45566. April 30, 1980. DANIEL A. BETTS, petitioner, vs. EVA MATIAS, respondent.
FACTS:

Petitioner Daniel Betts, owner of a two-storey residential building in Legaspi City, initially leased the entire property to respondent Eva Matias. Upon his retirement in 1973, the parties agreed Betts and his wife would occupy the ground floor while Matias would lease only the second floor. By 1976, the elderly Betts couple, suffering health issues from the cold and damp ground floor, proposed exchanging floors with Matias, who initially agreed. Matias later reneged, refusing to move. Betts, alleging the lease was month-to-month, terminated it and filed a complaint to fix a definite period for the lease’s termination, suggesting a date to allow Matias time to vacate.
The lower court dismissed the complaint. It reasoned that fixing a period under Article 1687 of the Civil Code would indirectly permit ejectment, violating the suspension of ejectment grounds under Presidential Decree No. 20 (P.D. 20). The court acknowledged potential inequity but felt constrained by the decree. Betts petitioned for review, arguing P.D. 20 was intended to protect the homeless poor, not a lessee like Matias who owned property and a vehicle.

ISSUE

Whether the lower court correctly dismissed the complaint for fixing a lease period on the ground it would indirectly violate the ejectment suspension under P.D. 20.

RULING

No. The Supreme Court reversed and remanded the case. The legal logic centers on interpreting P.D. 20 not as an absolute bar but as a measure for equitable relief. The Court, citing Onchengco vs. City Court of Zamboanga, reaffirmed that P.D. 20 was designed to alleviate housing shortages for the needy, not to deprive property owners of their rights in cases of extreme personal necessity. The suspension of Article 1673(1) of the Civil Code (judicial ejectment) is not inflexible.
Here, the petitioner-lessors, an elderly couple in deteriorating health needing to occupy the warmer second floor of their own home, presented a compelling case of extreme necessity. Denying them recourse would be inhumane and a deprivation of their constitutional right to property. The Court held that under these specific circumstances, the lessor is exempt from the P.D. 20 suspension. The authority of the court to fix a period under Article 1687, read with Article 1197 of the Civil Code, remains operative to do justice between the parties. The case was remanded for the trial court to receive evidence and, if the material allegations are proven, to fix a period terminating the lease and order possession delivered to Betts, while offering Matias the option to lease the ground floor at a reduced rental for one year.