G.R. No. L-45642 February 28, 1978
RAMON SALARIA, petitioner, vs. HON. CARLOS R. BUENVIAJE, Executive Judge, Court of First Instance of Camarines Sur, Branch VII, Iriga City and ANTONIO V. MENDIOLA, respondents.

FACTS

Petitioner Ramon Salaria had been a lessee of a residential lot owned by Eliodoro Cailao since 1930. The lease had no fixed period, with rentals initially at P6.00 monthly, later increased to P10.00. In December 1972, Cailao informed Salaria to stop paying rent and to vacate the land as he intended to sell it. The property was eventually sold to spouses Antonio Mendiola, with a deed dated June 15, 1974, though the sale was consummated earlier. After December 1972, no rentals were collected, prompting Salaria to consign P200.00 with the court. Despite demands to vacate, Salaria refused. Mendiola filed an unlawful detainer case, alleging need of the premises for personal use. Salaria moved to dismiss, arguing Presidential Decree No. 20 suspended ejectment under Article 1673(1) of the Civil Code. The city court ordered him to vacate within three months but excused him from paying back rentals. The Court of First Instance affirmed with modification, ordering immediate vacate upon finality and allowing Mendiola to withdraw the consigned amount.

ISSUE

The primary issue is whether private respondent Mendiola can eject petitioner Salaria on the ground of personal need, considering the lease had no definite period and is governed by Presidential Decree No. 20.

RULING

The Supreme Court reversed the lower courts’ decisions. The legal logic centers on the application of Presidential Decree No. 20, which suspended the provisions of Article 1673(1) of the Civil Code for leases without a definite period involving dwelling units or land. Article 1673(1) allows ejectment upon expiration of the lease period. Since the lease here had no fixed term, it fell under Article 1687, implying a year-to-year lease. Crucially, PD 20 explicitly suspended the lessor’s right to eject under Article 1673(1) “until otherwise provided,” removing expiration of an implied period as a ground for judicial ejectment. The Court rejected the argument that personal need of the premises constituted a valid exception, as PD 20’s suspension was categorical and allowed no such distinction. The construction by the implementing agency, the Department of Justice, which opined that ejectment for personal use was not permitted under the decree, was given significant weight. Furthermore, Salaria’s consignation of rentals after the owners refused payment constituted valid payment, absolving him of any default. Therefore, the ejectment action had no legal basis. The Court, however, ordered Salaria to pay any back rentals not covered by his deposit. The authorization for Mendiola to withdraw the consigned amount was sustained.