In David G. Dula vs. Dr. Restituto Maravilla and Teresita Maravilla, the Supreme Court affirmed that a month-to-month lease agreement, even without a fixed period, can expire and serve as grounds for ejectment, reinforcing landlords’ rights to reclaim property under certain conditions. This ruling clarifies that lessors can terminate such leases after proper notice, especially when they need the property for personal use, balancing the rights of property owners and tenants.

From Tenant’s Security to Landlord’s Need: Can a Month-to-Month Lease Really End?

This case began when the respondents, the Maravilla spouses, sought to eject petitioner David Dula from their apartment in Makati City. Dula had been renting the unit since 1968 under an oral month-to-month agreement. After purchasing the property in 1993, the Maravillas notified Dula of their intention to terminate the lease, citing their need for personal use of the premises. Dula refused to vacate, leading to an ejectment suit filed by the Maravillas in the Metropolitan Trial Court (MeTC) of Makati City. The central legal question revolved around whether a month-to-month lease could be terminated based on the lessor’s need for personal use and the expiration of the lease term, particularly in light of rent control laws.

The MeTC ruled in favor of the Maravillas, ordering Dula to vacate the premises and pay back rentals and attorney’s fees. The Regional Trial Court (RTC) affirmed this decision. Dula then appealed to the Court of Appeals (CA), arguing that the complaint lacked a cause of action because it did not explicitly state that the Maravillas owned no other residential unit in the same municipality, as required by Batas Pambansa (B.P.) Blg. 877, the rent control law at the time. The CA, however, affirmed the RTC’s decision with a modification, removing the award for attorney’s fees. Undeterred, Dula elevated the case to the Supreme Court, raising similar arguments.

The Supreme Court denied Dula’s petition, holding that there was substantial compliance with Section 5(c) of B.P. Blg. 877. While the original complaint may have been lacking, the Maravillas specifically stated in their Supplemental to Position Paper that they had no other property in Makati except the one in question. The Court emphasized that a defective complaint in summary procedure, such as an ejectment case, could be cured by allegations in the position paper.

Furthermore, the Court addressed Dula’s argument that the expiration of the month-to-month lease could not be a basis for ejectment because Section 6 of B.P. Blg. 877 suspended the application of Article 1687 of the Civil Code. The Court clarified that while Section 6 of B.P. Blg. 877 suspended Article 1673 of the Civil Code (which pertains to the grounds for ejectment), it did not suspend Article 1687. Article 1687 determines the period of the lease, specifying that if the rent is paid monthly, the lease is understood to be from month to month.

The Supreme Court cited its previous rulings, including De Vera vs. Court of Appeals and Rivera vs. Florendo, to support its position. These cases established that a month-to-month lease is considered a lease with a definite period, and upon the expiration of any month, the lessor may demand that the lessee vacate the premises. When the Maravillas notified Dula on January 10, 1994, of their need to use the property and demanded that he vacate, the contract of lease was deemed to have expired as of the end of that month, January 31, 1994.

Moreover, the Supreme Court highlighted Section 5(f) of B.P. Blg. 877, which allows ejectment based on the expiration of the lease contract. The Court noted that this provision no longer distinguishes between written and oral lease contracts. Thus, even though Dula’s lease agreement was oral, its expiration constituted a valid ground for ejectment.

The Court emphasized that all the elements required by Section 5(c) of B.P. Blg. 877 were present: the lessor’s legitimate need to repossess the property for personal use, the absence of other available residential units owned by the lessor in the same city, the expiration of the lease, and the formal notice given at least three months prior to the intended date of repossession. This convergence of factors led the Court to uphold the decisions of the lower courts, mandating Dula’s ejectment from the property.

FAQs

What was the key issue in this case?	The central issue was whether a month-to-month lease agreement could be terminated based on the lessor’s need for personal use and the expiration of the lease term, particularly under existing rent control laws.
What is the significance of Article 1687 of the Civil Code in this case?	Article 1687 of the Civil Code determines the period of the lease, specifying that if rent is paid monthly, the lease is understood to be from month to month. The Supreme Court clarified that this article was not suspended by rent control laws.
What is Section 5(c) of Batas Pambansa (B.P.) Blg. 877?	Section 5(c) of B.P. Blg. 877 allows for ejectment if the owner/lessor has a legitimate need to repossess the property for personal use and does not own any other available residential unit in the same city or municipality.
Can a complaint be cured by subsequent filings?	Yes, the Court held that a defective complaint in summary procedure, such as an ejectment case, could be cured by allegations in the position paper or supplemental filings, as long as the opposing party has the chance to rebut it.
What happens when a lessor gives notice to vacate in a month-to-month lease?	When the lessor gives proper notice to vacate, the contract of lease is deemed to have expired as of the end of the month. At that point the tenant is expected to leave the premises.
Does Section 5(f) of B.P. Blg. 877 distinguish between written and oral lease contracts?	No, Section 5(f) of B.P. Blg. 877 allows ejectment based on the expiration of the lease contract, regardless of whether it is written or oral.
What are the requirements for ejectment under Section 5(c) of B.P. Blg. 877?	The requirements are: (1) the lessor’s need for personal use, (2) the absence of other residential units owned by the lessor, (3) the expiration of the lease, and (4) a formal notice given at least three months prior to the repossession date.
What should a landlord do before filing an ejectment case?	Before filing an ejectment case, a landlord should ensure they have given the tenant proper notice to vacate, usually at least one month in advance for a month-to-month lease.

The Supreme Court’s decision in Dula v. Maravilla clarifies and reinforces the rights of lessors to reclaim their property when the need arises, even under month-to-month lease agreements. It balances tenant rights with the property rights of lessors, providing a clearer framework for resolving lease disputes and property ownership concerns.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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: DAVID G. DULA, VS. DR. RESTITUTO MARAVILLA AND TERESITA MARAVILLA, G.R. NO. 134267, May 09, 2005