GR L 75; (February, 1946) (Digest)
G.R. No. L-75; February 6, 1946
PHILIPPINE SUGAR ESTATES DEVELOPMENT CO., LTD., plaintiff-appellee, vs. GABRIELA PRUDENCIO, defendant-appellant.
FACTS
The defendant-appellant, Gabriela Prudencio, was occupying house No. 320 at P. Campa Street, Manila, under a monthly rent of P40. On March 19, 1945, the plaintiff-appellee, Philippine Sugar Estates Development Co., Ltd., served written notice to terminate the lease and demanded that she vacate the premises. When she failed to do so, the plaintiff filed an ejectment case in the Municipal Court of Manila. The Municipal Court rendered a decision on May 2, 1945, ordering the appellant to vacate and pay rents from April, plus costs. The appellant appealed to the Court of First Instance of Manila, which, after a trial de novo, affirmed the decision on July 30, 1945. The appellant appealed again to the Supreme Court.
ISSUE
Whether, under the circumstances of the case (post-war “abnormal conditions”), the court should temper or withhold the enforcement of the landlord’s legal right to eject a tenant based on principles of social justice, equity, or public policy.
RULING
The Supreme Court affirmed the appealed decision, ordering the appellant to vacate the premises and pay rents due. The Court held:
1. Under Article 1581 of the Civil Code, the plaintiff is entitled to the remedies sought for ejectment based on the undisputed facts.
2. The appellant’s arguments invoking “social justice,” “human rights,” and “abnormal conditions” to justify non-enforcement of the law are without merit. She failed to point to any specific legal ground or constitutional conflict that would warrant disregarding the applicable law.
3. The Court rejected the appellant’s “novel and experimental” proposition that ejectment should be withheld until normalcy is restored, emphasizing that the general invocation of “social justice” cannot be used to shirk the application of clear law.
4. The Court found the appellant’s position contrary to true social justice, noting her refusal to accommodate a war victim, Benjamin Ayesa—a naval commander and homeless war hero—in one room of the house, thereby demonstrating a lack of the Christian charity and universal brotherhood underlying the constitutional concept of social justice.
5. The Court refused to apply the appellant’s “unchristian and inhuman” interpretation of social justice, which it deemed egoistic and akin to “the rule of the jungle,” and upheld the lower courts’ decisions as correct.
Costs were imposed on the appellant.