Case Digest (G.R. No. 88632)
Facts:
- Teodulo Garcia (petitioner) purchased a parcel of land at No. 2372 Granate St., San Andres Bukid, Manila, registered in his name on September 25, 1979.
- The land was previously leased to Santos Gutierrez (respondent) by former owner Elvira Diguangco since February 1964.
- The lease agreement required Gutierrez to vacate upon the lessor's need for the land and did not specify a fixed term.
- Gutierrez constructed a house on the property and occupied it continuously since 1964.
- On November 19, 1978, Gutierrez promised to vacate within ninety days but failed to do so.
- After purchasing the property, Garcia demanded Gutierrez vacate, which he refused.
- Garcia filed a complaint for ejectment with the Barangay Chairman on September 19, 1982, which Gutierrez ignored.
- Garcia subsequently filed a civil case for ejectment with the Metropolitan Trial Court (MTC) on December 7, 1982, citing personal use of the property.
- Gutierrez opposed the action, claiming Garcia did not comply with Section 5(c) of Batas Pambansa Blg. 25, requiring a three-month notice.
- The MTC ruled in favor of Garcia, ordering Gutierrez to vacate and pay damages.
- Gutierrez appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision.
- After a denied motion for reconsideration, Gutierrez filed a Petition for Review with the Court of Appeals, which ruled in his favor, stating Garcia had not provided the required notice.
- Garcia then sought a review from the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Teodulo Garcia was not required to provide Santos Gutierrez with a new three-month notice to vacate, as the prior notice from the former owner sufficed.
- The Supreme Court held that the Metropolitan Trial Court had jurisd...(Unlock)
Ratio:
- The Supreme Court emphasized that the lease agreement effectively terminated when Elvira Diguangco notified Gutierrez to vacate.
- The lease was contingent upon the lessor's need for the property and did not specify a fixed term.
- Gutierrez's written promise to vacate within three months constituted an amendment to the lease, establishing a...continue reading
Case Digest (G.R. No. 88632)
Facts:
The case involves Teodulo Garcia as the petitioner and Santos Gutierrez as the respondent. The events leading to the case began when Teodulo Garcia purchased a parcel of land located at No. 2372 Granate St., San Andres Bukid, Manila, which was registered under his name on September 25, 1979. Prior to this purchase, the land was subject to a lease agreement between the former owner, Elvira Diguangco, and Santos Gutierrez, executed in February 1964. The lease agreement stipulated that Gutierrez was to vacate the premises upon the lessor's need for the land, and it did not specify a fixed term. Gutierrez constructed a house on the property and occupied it continuously since 1964.
In a letter dated November 19, 1978, Gutierrez promised to vacate the premises within ninety days, but he failed to do so. After purchasing the property, Garcia demanded that Gutierrez vacate the premises, but Gutierrez refused. On August 7, 1982, Garcia made another demand for Gutierrez to leave, which was again ignored. Consequently, Garcia filed a complaint for ejectment with the Barangay Chairman on September 19, 1982, which Gutierrez also disregarded. Garcia subsequently filed a civil case for ejectment before the Metropolitan Trial Court (MTC) of Manila on December 7, 1982, citing his need to repossess the property for personal use.
Gutierrez opposed the action, claiming that Garcia failed to comply with Section 5(c) of Batas Pambansa Blg. 25, which required a three-month notice prior to repossession. The MTC ruled in favor of Garcia, ordering Gutierrez to vacate and pay damages...