G.R. No. L-597; August 29, 1947
PURA KALAW LEDESMA y RAFAEL LEDESMA, demandantes-apelados, vs. EMILIO PICTAIN, demandado-apelante.

FACTS

This is an appeal from a judgment of the Court of First Instance of Manila, which affirmed a decision of the Municipal Court of Manila. The plaintiffs-appellees, Pura Kalaw Ledesma and Rafael Ledesma, filed an action for ejectment against the defendant-appellant, Emilio Pictain, concerning a property located at R. Hidalgo Street, No. 1100, Manila. The lower court ordered the defendant to vacate the premises, pay the monthly rent of P40 from August 1, 1945, until he vacates, and pay the costs. The judgment also authorized the defendant to remove the improvements he had introduced, leaving the property in its original condition.
The defendant, on appeal, does not dispute the factual findings of the lower court. He raises purely legal issues, contending that the court erred in not applying Commonwealth Act No. 689 to the case and in not dismissing the complaint for lack of cause of action. The appellant argues that with the approval of Act No. 689 on October 15, 1945, the month-to-month lease contract, which under Article 1581 of the Civil Code was understood to be from month to month, was automatically extended to six months. He further contends that the lease, beginning from the date the law took effect, was extended until April 15, 1946, and that the plaintiffs’ cause of action only arose after this date. Therefore, the complaint should have been dismissed.
The plaintiffs, on the other hand, need to occupy the property, as it is the only house left to them after their other houses were burned during the liberation. They currently live in a rented house on Valenzuela Street, paying a monthly rent of P250.

ISSUE

The primary legal issue is the correct interpretation and application of Commonwealth Act No. 689 (as amended by Republic Act No. 66) to a pre-existing month-to-month lease. Specifically, the Court must determine from what point the one-year lease term mandated by the amended law should be counted for a tenant who has been occupying the property for years under a tacit monthly renewal.

RULING

The Supreme Court, through Justice Pablo, affirmed the lower court’s decision.
The Court held that the purpose of Commonwealth Act No. 689, as amended by Republic Act No. 66, was to safeguard the welfare of inhabitants in war-damaged cities, preserve public health, and prevent disorder by using the state’s police power. The law provided that a month-to-month lease, in the absence of a stipulation on its duration, “shall be understood to have been made for one year.” This one-year period is to be counted “from the time the occupation under such contract began.”
The Court rejected the appellant’s interpretation. It examined three possible theories for counting the one-year period for a tenant who had been occupying the property for years (e.g., since January 1, 1940) under the Civil Code’s month-to-month provisions:
1. From the original occupation under the Civil Code (January 1, 1940). This was rejected as it would make the law’s one-year term illusory and absurd, as it would have already expired.
2. From the date of approval of Republic Act No. 66 (October 18, 1946). This was rejected as having no basis in the law’s text, which refers to the start of occupation under the contract, not the law’s effectivity.
3. From the first tacit renewal after the approval of the law (e.g., November 1, 1946). The Court adopted this third interpretation. It held that this construction best aligns with the legislative intent to provide a positive and reasonable remedy to the housing crisis. It prevents a discriminatory situation where a long-standing tenant would be in a worse position than a new tenant who began occupancy after the law’s passage. The cardinal reason for the law was to maintain the status quo to minimize war’s effects and restrict the grounds for ejectment.
The law mandates that “no tenant or occupant shall be ejected” except in specified cases: (a) voluntary and deliberate failure to pay rent; (b) when the lessor needs to occupy the building; or (c) when the tenant subleases without the lessor’s written consent. This provision is mandatory and applies to cases pending in court at the time of its approval. It is an emergency measure intended to last for four years from its approval.
Applying this to the case, the Court found that the plaintiffs’ need to occupy their only remaining property constituted a valid ground for ejectment under the law (the lessor’s necessity). Therefore, the trial court did not err in refusing to dismiss the complaint. The appealed judgment was confirmed, with costs against the appellant.
Separate Opinions:
Justice Perfecto concurred in the result.
Justice Feria dissented and concurred in part, arguing for a different application of the ejectment grounds.
* In a subsequent resolution on a motion for reconsideration (referenced in the appended dissents), Justices Perfecto, Hilado, and others dissented from the reversal of the original decision, arguing against the retroactive application of the laws involved.