G.R. No. L-52435 July 20, 1982
ELIZABETH SINCLAIR, petitioner, vs. COURT OF APPEALS, TANDIKO T. CENTI and JOSEPHINE CENTI, respondents.

FACTS

Respondent spouses, the lessors, filed an unlawful detainer case against petitioner-lessee Elizabeth Sinclair to recover possession of a residential house in Mandaluyong. The original one-year written lease expired on August 15, 1968, after which Sinclair was allowed to stay on a month-to-month basis under a verbal agreement. This agreement included a stipulation that the lease could be terminated once the lessors needed the house for their children’s use. In February 1974, respondents notified Sinclair to vacate by April 30, 1974, as their children needed to reside there for college. Sinclair refused, alleging the lease had no definite term and claiming the demand was a pretext to illegally increase rent under Presidential Decree No. 20.
The Municipal Court ruled for the lessors, ordering ejectment. The Court of First Instance of Rizal reversed, dismissing the complaint. It held that PD 20, which suspended Article 1673(1) of the Civil Code on ejectment upon expiration of the lease period, applied, thereby depriving the court of authority to order Sinclair’s ejectment. The Court of Appeals then reversed the CFI, reinstating the ejectment order, finding PD 20 inapplicable as there was no attempt to increase rent and the lessee was bound by her agreement to vacate upon demand.

ISSUE

Whether Presidential Decree No. 20 bars the ejectment of a month-to-month lessee based on a verbal agreement allowing termination when the lessor needs the property for personal use.

RULING

The Supreme Court affirmed the Court of Appeals, ruling that PD 20 does not apply to bar ejectment in this case. The legal logic is clear: PD 20 was enacted to protect lessees from arbitrary rent increases and ejectment due to expired leases during a housing crisis, by suspending Article 1673(1) of the Civil Code. However, its application is limited to its specific objectives: freezing rentals not exceeding P300, prohibiting demands for more than two months’ advance rent, and suspending ejectment solely under Article 1673(1) when the lease period expires.
Here, the basis for ejectment was not merely the expiration of a month-to-month period under Article 1687, which would be covered by the suspension. Instead, it was a violation of a specific condition in the verbal lease agreement—that the lessee would vacate when the owners needed the property for personal use. This falls under Article 1673(3) of the Civil Code (violation of conditions agreed upon), a ground for ejectment not suspended by PD 20. The Court found no attempt to increase rent, so the protective mantle of PD 20 was unavailing. The lessee was thus bound by her agreement, and her refusal to vacate constituted unlawful detainer.