Facts:

The case involves the Spouses Ricardo and Lourdes Cortez as petitioners against Judge Serafin E. Camilon, the Presiding Judge of the Court of First Instance of Rizal, Pasig Branch VIII, and Recaredo Coronel as respondents. The events leading to this case began when the Cortez spouses were living in an apartment located at 4541-D Quintos Street, Makati, Metro Manila. The dispute arose when Recaredo Coronel, the landlord, sought to eject the Cortez spouses from the premises, claiming that he needed the apartment for his daughter, Grace Coronel-Valdez, who was residing with her in-laws on the same street. The Cortez spouses had a month-to-month lease agreement, which they argued had not expired, and thus, they contended that the ground for ejectment cited by the landlord was not applicable. The case was initially heard in the Makati Municipal Court, which ruled in favor of the landlord. The Cortez spouses appealed the decision to the Court of First Instance of Rizal, which affir...

Facts:

1. Parties Involved:

   • Petitioners: Spouses Ricardo and Lourdes Cortez (tenants).
   • Respondents: Judge Serafin E. Camilon (Presiding Judge of the Court of First Instance of Rizal, Pasig Branch VIII) and Recaredo Coronel (landlord).

2. Subject Property:

   • The apartment located at 4541-D Quintos Street, Makati, Metro Manila.

3. Nature of Lease:

   • The lease was on a month-to-month basis.

4. Ground for Ejectment:

   • The landlord, Recaredo Coronel, sought to eject the Cortez spouses to repossess the apartment for the use of his daughter, Grace Coronel-Valdez, who was residing with her in-laws on the same street.

5. Legal Proceedings:

   • The Makati municipal court ruled in favor of the landlord, ordering the Cortez spouses to vacate the property.
   • The Court of First Instance of Rizal affirmed the municipal court's decision.
   • The Cortez spouses appealed, arguing that the ground for ejectment (landlord's need for the property) applies only when the lease has expired, which was not the case here since the lease was month-to-month and had not expired.

6. Relevant Laws Cited:

   • Article 1673 of the Civil Code (grounds for judicial ejectment).
   • Article 1687 of the Civil Code (duration of lease when no fixed period is agreed upon).
   • Presidential Decree No. 20 (freezing rentals and suspending certain provisions of Article 1673).
   • Batas Pambansa Blg. 25 (specifying grounds for ejectment for residential units with rentals not exceeding P300).

Issue:

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Ruling:

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Ratio:

1. Applicability of Batas Pambansa Blg. 25:

   • The Court clarified that Batas Pambansa Blg. 25 allows ejectment based on the landlord's need to repossess the property for the use of an immediate family member, provided that the lessor or immediate family member does not own any other available residential unit and that the lessor has given the lessee three months' notice.
   • This ground for ejectment applies regardless of whether the lease is for a fixed period or month-to-month.

2. Suspension of Article 1673(1) of the Civil Code:

   • Presidential Decree No. 20 and Batas Pambansa Blg. 25 suspended the application of Article 1673(1) of the Civil Code, which allows ejectment upon the expiration of the lease period. However, this suspension does not affect other grounds for ejectment, such as the landlord's need for the property.

3. Legitimacy of the Landlord's Claim:

   • The Court found that the landlord's need to repossess the property for his daughter's use was legitimate and complied with the requirements under Batas Pambansa Blg. 25.

4. Fallacy of the Tenants' Argument:

   • The Cortez spouses' contention that the ground for ejectment applies only when the lease has expired was deemed fallacious. The Court emphasized that the landlord's need for the property is a separate and valid ground for ejectment under the law.