Facts:

The case revolves around Maximo Aquino as the petitioner versus the Intermediate Appellate Court and respondents Pedro Peralta and Lolita Peralta. The events in question transpired at 31 19th Avenue, Cubao, Quezon City. The origins date back to a written lease agreement between Aquino and Maximo Siobal, set at a monthly rental of ten pesos, integrating a 50-square meter portion of land. It was presumed that this lease extended for fifteen years and that the real occupant was Exequiel Peralta, who is Siobal's uncle and had constructed a house on the property. In 1967, Exequiel sold the house to his nephew, Pedro Peralta, who had been cohabiting with him since 1962. The contract was set to expire in 1975, but Aquino agreed to extend it until February 18, 1976, following a request from Lolita Peralta, Pedro’s wife. After the lease expired, Aquino sought possession of the property, confronting the Peralta couple with demands to vacate, which they disregarded. Consequently, on Ja

...

Facts:

Background of the Property and Lease Agreement

• The disputed property is a 50-square meter portion of a lot located at 31 19th Avenue, Cubao, Quezon City.
• The owner, Maximo Aquino, intended to construct a five-door apartment on the lot for the use of his five married children who were residing in rented houses.
• A written lease was executed with Maximo Siobal, stipulating a monthly rental of ten pesos.
• However, the parties and lower courts assumed that the lease was for a period of fifteen years, and that the actual lessee was Exequiel Peralta, who was Maximo Siobal’s uncle.

Development of the Lease and Occupancy

• It was alleged that Exequiel Peralta built a house on the leased portion.
• In 1967, the house was sold by Exequiel Peralta to his nephew, Pedro Peralta, who had reportedly been residing with him since 1962.
• Upon the lease’s expiration in 1975, Maximo Aquino refused to extend the lease.
• On the pleadings of Pedro Peralta’s wife, an extension was granted until February 18, 1976.
• Other occupants of the lot had voluntarily vacated, isolating the dispute to the Peralta spouses.

Initiation of the Ejectment Case

• After the extended lease period ended, Aquino demanded that the Peralta spouses vacate the lot.
• When the Peraltas refused to restore possession, Aquino filed an ejectment suit in the City Court on January 2, 1980.
• The City Court and subsequently the Regional Trial Court ordered the Peraltas to vacate, basing their decisions on section 5(c) of Batas Pambansa Blg. 25.

Application of the Urban Land Reform Law

• The Peralta spouses contested the ejectment citing the Urban Land Reform Law which, under Section 6, protects legitimate tenants who meet specific residency and occupancy criteria within designated urban zones.
• The lower appellate body (Intermediate Appellate Court) held that the ejectment was not sanctionable because the area in question should be covered by the said law, which guarantees the right of legitimate tenants not to be dispossessed.

Determination of the Relevant Area

• The Supreme Court clarified that 19th Avenue, Quezon City, is not an urban land reform zone nor one of the sixty-six blighted areas for priority development as enumerated in Proclamation No. 1967 dated May 14, 1980.
• The reference in the law to a blighted area in No. 36 specifically mentioned the “5th to 7th Avenue” area, thereby excluding the dispute area.

Status of the Peralta Spouses

• The facts unequivocally showed that the Peralta spouses were not the legitimate tenants as envisaged by Section 6 of the Urban Land Reform Law.
• Their occupancy did not satisfy the requisite criteria of continuous residence and construction of a home on the land as mandated by the law.

Issue:

Application of the Urban Land Reform Law

• Whether the Urban Land Reform Law barred the ejectment of the Peralta spouses from the disputed portion of the lot.
• Whether the disputed property falls within an urban land reform zone or one of the designated sixty-six blighted areas for priority development.

Tenancy and Legitimacy

• Whether the Peralta spouses qualify as legitimate tenants under Section 6 of the Urban Land Reform Law.
• Whether the extended lease agreement and occupancy established a tenancy that warranted protection under the law.

Judicial Interpretation and Statutory Construction

• How the lower courts’ interpretation of the Urban Land Reform Law aligned with the explicit criteria provided in Section 6.
• Whether the extension of the lease period and the subsequent occupancy should override the statutory limitations imposed by the law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)