Spouses Teofilo Ercillo v. Court of Appeals

Summary

This unlawful detainer case involved spouses Ercillo who leased an apartment from spouses Cifra. When lessors filed ejectment for non-payment of rent from August 1976, lessees claimed they deposited unpaid rentals with a bank after lessors refused payment, then with Office of Civil Relations, and finally with the court. The Supreme Court affirmed lower courts' decisions, ruling that bank deposits do not constitute valid consignation under Civil Code Articles 1256-1258, which require deposit with judicial authority. The Court also held that LOI 768, which would have allowed bank deposits as alternative to court consignation, was issued in 1978 but could not apply retroactively to the 1976 ejectment case. The decision clarifies the strict requirements for valid consignation and the non-retroactive application of remedial regulations in landlord-tenant disputes.