Estrada vs. Caseda

An amendatory act is construed as if the original statute had been originally enacted in its amended form, so that the effectivity period of the amended statute is computed from the date of approval of the original act, not from the date of the amendment. Where an amendment leaves certain portions of the original act unchanged, such portions are continued in force with the same meaning and effect they had before the amendment, and are regarded as a continuation of the existing law, not as a new enactment.

The case involves a lease agreement between Demetria Estrada, as lessor, and Uldarico Caseda, as lessee, over a part of a dwelling at a monthly rental of P26. The dispute arose within the context of rent control legislation—Commonwealth Act No. 689, approved October 15, 1945, which regulated the ejectment of lessees from buildings destined solely for dwelling purposes. The Act originally provided for a two-year effectivity period, which was later extended to four years by Republic Act No. 66, approved October 18, 1946. The statutory framework limited the grounds for ejectment to three specific circumstances, none of which included the lessor's need to house a married daughter.

On September 5, 1945, Demetria Estrada brought an unlawful detainer suit against Uldarico Caseda, alleging that the defendant leased from her a part of a dwelling at a monthly rental of P26. On August 11, 1945, the plaintiff notified the defendant in writing to vacate the leased premises because one of her married daughters was going to occupy them by the first of the following month. The defendant refused to leave.

On October 13, 1945, Judge Mariano Nable of the municipal court rendered judgment for the plaintiff, ordering the defendant to pay rent from October 1, 1945, at the rate of P26 a month. On appeal to the Court of First Instance, the defendant filed an answer alleging as a special defense, among others not necessary to the solution of the appeal, that the main motive of the plaintiff in bringing the action was to oust the defendant and lease the premises to third parties willing to pay black market rental.

In reversing the municipal court judgment, the Court of First Instance, Judge Rafael Dinglasan presiding, held that Commonwealth Act No. 689, as amended, provided only three grounds for ejecting a lessee from a building destined solely for dwelling: (1) willful and deliberate non-payment of rents, (2) when the lessor has to occupy the building leased, and (3) when the lessee shall have subleased the building or any part thereof as dwelling or for dwelling purposes without the written consent of the proprietor. The trial court found that none of these conditions was alleged, much less proved, and correctly held that the fact that the premises were needed by the plaintiff's married daughter was not comprehended in the second ground.

Commonwealth Act No. 689 was approved October 15, 1945, and Section 14 of that Act provided that it "shall be in force for a period of two years after its approval." Republic Act No. 66, approved October 18, 1946, amended Section 14 to provide that the Act "shall be in force for a period of four years after its approval." The question presented on appeal was whether this four-year period commenced to run from the approval of the original act or from the approval of the amendatory act, and whether the lease was still within that period.

• Statutory Ground for Ejectment: The plaintiff-appellant sought review of the Court of First Instance's decision, which had reversed the municipal court judgment and declared that the plaintiff may not eject the defendant from the premises. The plaintiff's action was premised on the allegation that her married daughter needed the premises, a ground not among those enumerated in Commonwealth Act No. 689.

• Effectivity of the Amended Act: The plaintiff-appellant's appeal necessarily required the Court to determine whether the four-year effectivity period under Republic Act No. 66, amending Section 14 of Commonwealth Act No. 689, was computed from the date of approval of the original act or from the date of the amendment, and whether the lease was still within that period.

• Special Defense — Black Market Rental: The defendant-appellee alleged in his answer before the Court of First Instance, as a special defense, that the main motive of the plaintiff in bringing the action was to oust the defendant and lease the same premises to third parties who were willing to pay black market rental.

• Statutory Grounds Not Alleged or Proved: The defendant-appellee successfully argued before the Court of First Instance that none of the three grounds for ejectment under Commonwealth Act No. 689, as amended, was alleged, much less proved, and that the need of the premises by the plaintiff's married daughter was not comprehended in the second ground.

• Statutory Ground for Ejectment: Whether the need of the leased premises by the lessor's married daughter constitutes a ground for ejectment under Commonwealth Act No. 689, as amended.

• Effectivity of the Amendatory Act: Whether the four-year effectivity period under Republic Act No. 66, amending Section 14 of Commonwealth Act No. 689, should be computed from the date of approval of the original act (October 15, 1945) or from the date of approval of the amendatory act (October 18, 1946).

• Statutory Ground for Ejectment: No. The need of the premises by the lessor's married daughter is not comprehended in the second ground of Commonwealth Act No. 689, which requires that the lessor himself or herself has to occupy the building leased. The Court of First Instance correctly held that this ground was not among those enumerated in the Act.

• Effectivity of the Amendatory Act: The four-year period commenced to run from October 15, 1945, the date of approval of the original act, and expired on October 15, 1949. An amendatory act is construed as if the original statute had been originally enacted in its amended form, so the amendment relates back to the date of the original act's approval.

• Statutory Ground for Ejectment: Commonwealth Act No. 689, as amended, provides only three grounds for rejecting a lessee or occupant from a building destined solely for dwelling: (1) willful and deliberate non-payment of rents, (2) when the lessor has to occupy the building leased, and (3) when the lessee shall have subleased the building or any part thereof as dwelling or for dwelling purposes without the written consent of the proprietor. The Court of First Instance correctly held that the fact that the premises under lease were needed by the plaintiff's married daughter was not comprehended in the second ground, which contemplates the lessor's own need to occupy the premises.

• Effectivity of the Amendatory Act: The Court applied the general rule of statutory construction that an amended act is ordinarily to be construed as if the original statute had been repealed and a new and independent act in the amended form had been adopted in its stead. As frequently stated by the courts, so far as regards any action after the adoption of the amendment, the statute is treated as if it had been originally enacted in its amended form. The amendment becomes a part of the original statute as if it had always been contained therein, unless such amendment involves the abrogation of contractual relations between the state and others. Where an amendment leaves certain portions of the original act unchanged, such portions are continued in force with the same meaning and effect they had before the amendment. Where an amendatory act provides that an existing statute shall be amended to read as recited in the amendatory act, such portions of the existing law as are retained, either literally or substantially, are regarded as a continuation of the existing law, and not as a new enactment. In accordance with this rule, the provision of Republic Act No. 66 amending Section 14 of Commonwealth Act No. 689 related back to, and should be computed from, the date of approval of the amended act, that is, October 15, 1945. The period as thus construed expired on October 15, 1949. Since the period reckoned by the trial court was now over, the Court rendered judgment ejecting the defendant and ordering him to pay rent at the rate of P26 a month from October 1, 1945.

• Doctrine of Relation Back of Amendatory Statutes — An amendatory act is construed as if the original statute had been originally enacted in its amended form. The amendment becomes a part of the original statute as if it had always been contained therein, unless such amendment involves the abrogation of contractual relations between the state and others. The Court applied this doctrine to hold that the four-year effectivity period under Republic Act No. 66 was computed from the date of approval of the original act, Commonwealth Act No. 689, which was October 15, 1945.

• Doctrine of Continuation of Unchanged Portions — Where an amendment leaves certain portions of the original act unchanged, such portions are continued in force with the same meaning and effect they had before the amendment. Where an amendatory act provides that an existing statute shall be amended to read as recited in the amendatory act, such portions of the existing law as are retained, either literally or substantially, are regarded as a continuation of the existing law, and not as a new enactment. The Court relied on this principle to conclude that the effectivity period should be computed from the original act's approval date.

• "An amended act is ordinarily to be construed as if the original statute had been repealed, and a new and independent act in the amended form had been adopted in its stead; or, as frequently stated by the courts, so far as regards any action after the adoption of the amendment, as if the statute had been originally enacted in its amended form." — This passage states the foundational rule of statutory construction applied by the Court to determine the effectivity period of the amended rent control law.

• "The amendment becomes a part of the original statute as if it had always been contained therein, unless such amendment involves the abrogation of contractual relations between the state and others." — This excerpt articulates the doctrine of relation back, which was the controlling principle for computing the four-year period from the original act's approval date.

• "In accordance with this rule, the provision of Republic Act No. 66 amending section 14 of Commonwealth Act No. 689, related back to, and should be computed from the date of the approval of the amended act, that is October 15, 1945. The period as thus construed expired on October 15, 1949." — This passage applies the doctrine to the facts of the case and establishes the dispositive timeline that led to the defendant's ejectment.

• 59 C. J., 1096, 1097 — Cited as the general authority for the rules of statutory construction governing amendatory acts, including the doctrines that an amended act is construed as if originally enacted in its amended form, that the amendment becomes part of the original statute, and that unchanged portions are continued in force with the same meaning and effect.

• Section 14, Commonwealth Act No. 689 — The original rent control statute provided that it "shall be in force for a period of two years after its approval." The Court interpreted this provision in light of the subsequent amendment to determine the applicable effectivity period.

• Section 14, Commonwealth Act No. 689, as amended by Republic Act No. 66 — The amendatory act provided that the Act "shall be in force for a period of four years after its approval." The Court construed this provision as relating back to the original act's approval date of October 15, 1945, making the period expire on October 15, 1949.

Ozaeta, Paras, Feria, Montemayor, Reyes, and Torres, JJ., concurred. Chief Justice Moran noted that Mr. Justice Bengzon voted in conformity with the decision.

• Justice Padilla (concurring) — Justice Padilla concurred in the result but on a different ground, stating that Commonwealth Act No. 689, as amended by Republic Act No. 66, cannot be given retroactive effect because the cause of action in the case at bar arose before the passage of the Acts.