T & C Development Corp. v. Court of Appeals

Summary

T&C Development Corp. sought to eject tenant Eligio de Guzman for non-payment of increased rental rates. De Guzman occupied an apartment unit, using the ground floor for business and second floor as residence. When T&C increased rent from P700.00 to P1,800.00, de Guzman refused and continued paying only the original amount. The Supreme Court ruled that the premises were residential under rent control laws, limiting allowable increases to 20% annually. However, the Court granted ejectment because de Guzman's failure to pay for over three months constituted valid grounds under Article 1673 of the Civil Code and the Rent Control Law. The Court ordered payment of graduated rental increases based on updated rent control legislation, from P840.00 monthly in late 1992 to P2,764.27 by 1999, establishing that proper consignation procedures must be followed when disputing rental increases.