Republic v. Peralta

G.R. No. 184253 (July 6, 2011)

SC upholds Navy's right to evict retirees from military housing post-lease expiration.

Facts:

The case involves a dispute between the Republic of the Philippines, represented by the Philippine Navy, and several retired military personnel who were occupying military quarters at the Bonifacio Naval Station (BNS) in Makati City. The respondents, who were all retired members of the Philippine Navy and Marines, had been awarded military quarters during their active service and had entered into contracts of lease with the BNS Commander for their occupation of these quarters. Despite their retirement, they continued to occupy the assigned quarters.

In February 1996, the Navy Enlistedmen Homeowners Association, Inc. (NEHAI), which included the respondents, filed a petition for declaratory relief against various government entities, claiming a right of first priority to purchase the MEQ property under certain proclamations and laws. Subsequently, the BNS Commander issued eviction notices to the respondents, prompting them to seek legal recourse. They filed a complaint for injunction against the Philippine Navy to prevent their eviction, which was granted by the Regional Trial Court (RTC) of Makati City, stating that the BNS Commander could not evict them without a court order.

The petitioner, the Republic of the Philippines, sought to overturn the RTC's decision through a petition for certiorari before the Court of Appeals, arguing that the respondents' contracts of lease had expired upon their retirement, thus allowing for extrajudicial eviction.

Legal Issues:

The primary legal issue in this case is whether the petitioner, the Republic of the Philippines, is required to file an ejectment suit before evicting the respondents and intervenors from the military housing quarters, given that their contracts of lease had expired upon their retirement.

Arguments:

  • Petitioner's Argument: The petitioner contended that the contracts of lease explicitly allowed for extrajudicial repossession of the leased property upon the expiration of the lease, which occurred when the respondents retired from military service. The petitioner argued that the occupancy of the military quarters was contingent upon active service, and therefore, the respondents had no legal right to remain in the quarters after their retirement. The petitioner cited contractual stipulations and military regulations that supported its position.

  • Respondents' Argument: The respondents argued that they could not be evicted without a court order, as the RTC had previously granted them a preliminary injunction against eviction. They maintained that their continued occupancy was justified based on their membership in NEHAI and the pending petition for declaratory relief regarding their rights to the property.

Court's Decision and Legal Reasoning:

The Court of Appeals initially ruled in favor of the respondents, affirming the RTC's decision that the petitioner could not evict them without a court order. However, upon review, the Supreme Court found merit in the petitioner's arguments. The Court held that the contracts of lease clearly stipulated that the respondents were required to vacate the quarters upon their retirement. The Court emphasized that the military quarters were intended for active military personnel and that the lease agreements included provisions allowing for extrajudicial repossession.

The Court referenced previous jurisprudence that upheld the validity of lease stipulations permitting landlords to reclaim possession of leased properties upon expiration of the lease. It concluded that the respondents' continued occupancy was unauthorized after their retirement, and thus, the petitioner was entitled to extrajudicially evict them without the need for a judicial action.

Significant Legal Principles Established:

  1. Extrajudicial Eviction Validity: The Court reaffirmed that contractual stipulations allowing a lessor to repossess leased property upon expiration of the lease are valid and enforceable, particularly in the context of military housing.

  2. Military Quarters Occupancy: The ruling clarified that military quarters are designated for the exclusive use of active military personnel, and retired personnel lose their right to occupy such quarters upon retirement.

  3. Judicial Process Requirement: The decision highlighted the importance of adhering to the terms of lease agreements and military regulations, indicating that judicial processes may not be necessary for eviction when clear contractual terms exist.