TL;DR

The Supreme Court ruled that a month-to-month lease is considered a lease with a definite period, which can be terminated at the end of any month if the lessor demands the lessee to vacate. This means landlords can legally evict tenants when a month-to-month lease expires, provided proper notice is given. This decision clarifies the rights of property owners to regain possession of their property upon lease expiration, balancing those rights with the protections afforded to tenants under Philippine law. It underscores the importance of understanding lease terms and notice requirements to avoid legal disputes regarding eviction.

Month-to-Month Mayhem: Can Landlords Evict After Lease ‘Expiration’?

This case revolves around Consolacion de Vera’s eviction from an apartment unit she leased in Manila. After the property changed ownership, the new landlord, Quayalay Realty Corporation, sought to terminate her month-to-month lease. The central legal question is whether such a lease can be considered to have a definite period, allowing for eviction upon its expiration, despite rent control laws designed to protect tenants. This decision clarifies the interplay between property rights, lease agreements, and tenant protections under Philippine law.

De Vera had been leasing the apartment since 1967. Initially, the rent was P150.00, but by 1990, it had increased to P924.00. When Llantos, Lim & Sons, Inc. sold the apartment to Quayalay Realty Corporation, De Vera was notified that her month-to-month lease would not be renewed after December 30, 1990. Quayalay Realty subsequently demanded that De Vera vacate the premises, leading to an ejectment suit when she refused.

The Metropolitan Trial Court (MeTC) ruled in favor of Quayalay Realty, finding that the lease was indeed on a month-to-month basis and had not been renewed. This decision was affirmed by the Regional Trial Court (RTC), although the award of attorney’s fees was increased. The Court of Appeals (CA) also upheld the MeTC’s decision but removed the attorney’s fees. De Vera then elevated the case to the Supreme Court, arguing that her lease was for an indefinite period and that Quayalay Realty had no grounds for ejectment. De Vera based her argument on the fact that the lease was verbal, and no specific end date was ever agreed upon.

The Supreme Court, however, disagreed with De Vera’s contentions. The Court cited Article 1687 of the Civil Code, which states that if the rent is paid monthly, the lease is understood to be from month to month. This effectively defines a month-to-month lease as one with a definite period, terminable at the end of each month upon demand. Furthermore, the Court clarified that while Section 6 of Batas Pambansa (B.P.) Blg. 877 suspends certain provisions of the Civil Code related to lease, it does not suspend Article 1687 entirely. The suspension only prevents lessors from ejecting tenants solely based on lease expiration; it doesn’t negate the applicability of Art. 1687 in determining the lease period.

The Supreme Court also addressed De Vera’s argument that Quayalay Realty was bound to respect the lease. The Court reasoned that with the expiration of the lease, there was no longer a contract to bind the new owner. Additionally, the Court dismissed De Vera’s claim that the Court of Appeals had improperly fixed the lease period. It emphasized that Article 1687 itself defines the period based on the frequency of rent payments. The Court also noted that because of the length of the legal proceedings, De Vera’s stay had already been extended for a considerable time, providing her ample opportunity to find alternative housing. In effect, the Court balanced the landlord’s right to possess their property with the tenant’s right to security of tenure, finding that the former outweighed the latter in this specific case.

The Court referenced previous rulings, such as Legar Management Realty v. Court of Appeals, to reinforce its position that a lease on a month-to-month basis has a definite period. Section 5(f) of B.P. Blg. 877, as amended, explicitly includes the expiration of the lease contract as a ground for ejectment, regardless of whether the contract is written or oral. The case highlights the importance of understanding that even without a written agreement, a lease can have a defined period based on payment intervals, and landlords can pursue eviction upon its expiration, provided proper notice is given.

FAQs

This case provides important clarity on the rights and obligations of landlords and tenants in the Philippines. Understanding the nuances of lease agreements and applicable laws is crucial for both parties to avoid potential disputes and ensure fair treatment. The ruling emphasizes the importance of being aware of the terms of a lease, even if it’s unwritten, and how those terms affect the right to occupy a property.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Consolacion de Vera v. Court of Appeals, G.R. No. 110297, August 07, 1996