G.R. No. 91406 , July 31, 1990
HEIRS OF JULIO ROSAS, represented by MERCEDES ROSAS, petitioners, vs. HON. OSCAR R. REYES, Presiding Judge of Pasay City Branch 47, Metropolitan Trial Court, CHARRY CARANAY and SANTIAGO I. BARCENAS, respondents.

FACTS

The petitioners, owners of a residential apartment in Pasay City, filed an unlawful detainer suit against the private respondents, their lessees, after the latter refused to agree to a rental increase and the petitioners refused to accept subsequent rental payments. The Metropolitan Trial Court (MTC) ruled for the petitioners. On appeal, the Regional Trial Court (RTC) reversed the MTC, dismissing the complaint. The RTC found that an implied new lease was created under Article 1670 of the Civil Code due to the lessee’s continued occupancy and the lessor’s failure to give a timely notice to vacate before the original lease expired. Applying Article 1687, the RTC fixed a definite new lease period of six months, ending April 30, 1988, ordering the lessees to vacate by that date. This RTC decision was affirmed by the Court of Appeals.
After April 30, 1988, the petitioners filed a motion for execution in the MTC to enforce the RTC’s order for the lessees to vacate. The respondent MTC judge denied the motion, ruling that the portion of the RTC dispositive part fixing the six-month period was a “mere directive” and not an executory judgment. The judge advised the petitioners to file a new ejectment case. The petitioners moved for reconsideration, which was denied, prompting this petition for certiorari.

ISSUE

Whether, after a court creates an implied new lease and fixes a definite period for its expiration, the lessor may eject the lessee upon that expiration through a mere motion for execution, or must file a new ejectment action.

RULING

The Supreme Court granted the petition. The RTC’s dispositive portion, which fixed a new six-month lease ending April 30, 1988, constituted an executory judgment that could be enforced by a mere motion for execution. The respondent MTC judge erred in treating it as a non-executory directive. The legal logic is anchored on the finality of the RTC decision. Having determined that an implied new lease existed under Article 1670, the court properly applied Article 1687 to set a definitive term. Once that court-fixed period lapsed, the lessee’s right to possess legally terminated. Requiring a new ejectment suit would be redundant, violate the doctrine of finality of judgments, and frustrate the summary nature of ejectment proceedings. It would needlessly clog court dockets. The Court emphasized that the lessor’s remedy upon the expiration of a court-fixed period in an implied new lease is execution, not a new action. The Court also ordered the private respondents to pay all unpaid rentals until vacation, rejecting an alleged unauthorized condonation agreement and noting their unjust enrichment from using the premises without payment. However, the Court found no basis for administrative sanctions against the respondent judge, as the error was one of judgment, not malice.