- Petitioner
- Maura Inductivo
- Respondent
- The Hon. Court of Appeals
- Citation
- G.R. No. 108196
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Vitug, J.
- Decided
- January 19, 1994
Summary
This case involved a landlord-tenant dispute where lessor Maura Inductivo sought to eject lessee Vicky Dimapilis from a month-to-month lease arrangement. The key issues were whether bank deposits constituted valid rental payments when the landlord refused to accept them, and whether a month-to-month lease could be terminated upon notice under the Rent Control Law. The Supreme Court ruled that deposits with Philippine Savings Bank under B.P. 25 constituted valid payment, preventing ejectment for non-payment. However, the Court held that month-to-month leases create definite periods expiring each month, allowing lessor termination rights as an exception to the Rent Control Law. The decision clarified that Articles 1670 and 1687 of the Civil Code create implied new leases for periods determined by rental payment frequency, establishing legal precedent for month-to-month lease termination rights.