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...

Facts:

1. Purchase of the Land:

   • Petitioner Teodulo Garcia purchased a parcel of land located at No. 2372 Granate St., San Andres Bukid, Manila. The land was registered under his name on September 25, 1979, with the Register of Deeds of Manila.

2. Lease Agreement:

   • Before the purchase, the land was leased by the former owner, Elvira Diguangco, to private respondent Santos Gutierrez under a lease agreement executed in February 1964. The lease contract contained the following key provisions:
     • Clause 2: The lessee (Gutierrez) agreed to vacate and remove his house from the land upon the lessor's (Diguangco) need for the property.
     • Clause 8: The lease had no fixed term and would continue until the lessor needed the land for personal use.

3. Construction and Occupation:

   • Gutierrez constructed a house on the land and had been occupying it since 1964.

4. Promise to Vacate:

   • On November 19, 1978, Gutierrez executed a written promise to vacate the land and remove his improvements within 90 days. However, he failed to comply with this promise.

5. Demands to Vacate:

   • After purchasing the land, Garcia demanded that Gutierrez vacate the premises, but Gutierrez refused.
   • On August 7, 1982, Garcia again demanded that Gutierrez vacate, but Gutierrez still refused.
   • Garcia sought the intervention of the Barangay Chairman, who issued a summons on September 19, 1982, which Gutierrez ignored.

6. Filing of Ejectment Case:

   • On December 7, 1982, Garcia filed a civil case for ejectment before the Metropolitan Trial Court (MTC) of Manila, citing his need to repossess the property for personal use.

7. Defense of Private Respondent:

   • Gutierrez opposed the ejectment, arguing that Garcia failed to comply with Section 5(c) of Batas Pambansa Blg. 25 (B.P. Blg. 25), which required a three-month advance notice of intent to repossess the property.

8. Trial Court Decision:

   • The MTC ruled in favor of Garcia, ordering Gutierrez to vacate the premises and pay P2,000.00 in damages. Gutierrez's counterclaim was dismissed.

9. Appeal to RTC:

   • Gutierrez appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision.

10. Appeal to Court of Appeals:

    • The Court of Appeals reversed the RTC's decision, ruling that Garcia failed to give the required three-month notice under B.P. Blg. 25.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Subrogation of Rights:

   • When Garcia purchased the land, he acquired all the rights of the former owner, including the right to enforce the lease agreement and the notice to vacate given to Gutierrez. There was no need for Garcia to issue a new three-month notice.

2. Expiration of Lease:

   • The lease agreement, as amended by Gutierrez's written promise to vacate, had a fixed term that expired on February 19, 1979. Upon expiration, Garcia had the right to eject Gutierrez under Section 5(f) of B.P. Blg. 25.

3. Jurisdiction:

   • The MTC had jurisdiction over the ejectment case because the complaint was based on the expiration of the lease and the lessee's refusal to vacate, which are matters within the MTC's jurisdiction.

4. Policy of Rent Control Law:

   • While B.P. Blg. 25 was enacted to protect tenants, it also recognizes the rights of lessors, especially when they need the property for personal use and have no other available residential unit.