Case Digest (G.R. No. 76294)
Facts:
- Marlene Madriaga (petitioner) leased a two-storey commercial building in Manila from the Rodriguezes and Chicos in 1973 for her pharmaceutical business.
- Madriaga subleased parts of the upper floor: one to Dr. Rogelio Sangalang in August 1973 for a dental clinic and another to Mila Hatanaka in 1974 for residential use, both at P300.00 monthly.
- The sublease agreements allowed Madriaga to reclaim the premises upon notifying the sublessees if needed for her business.
- By 1978, Madriaga's business expanded, leading her to renew her lease and terminate the subleases.
- Sangalang vacated as required, but Hatanaka refused to leave.
- Madriaga filed an ejectment action against Hatanaka, which was initially dismissed by the Metropolitan Trial Court.
- The Regional Trial Court reversed the dismissal and ordered Hatanaka's eviction.
- Hatanaka appealed to the Court of Appeals, which ruled in her favor, dismissing Madriaga's complaint.
- Madriaga subsequently filed a petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted Madriaga's petition, reversing the Court of Appeals' decision.
- The Court ordered Hatanaka to vacate the premises an...(Unlock)
Ratio:
- The Supreme Court determined that the classification of the premises occupied by Hatanaka was crucial in assessing the applicability of B.P. Blg. 25.
- The character of a property is defined by its intended use; although the building was commercial, Hatanaka's use was residential, bringing it under the Rent Control Law.
- The temporary nature of the agre...continue reading
Case Digest (G.R. No. 76294)
Facts:
The case involves Marlene Madriaga as the petitioner and Mila Hatanaka as the respondent, with the decision rendered by the Court of Appeals on October 8, 1986. The events leading to the case began in 1973 when Madriaga leased a two-storey commercial building located at the corner of San Andres and Leveriza Streets in Manila from the Rodriguezes and Chicos. The primary purpose of the lease was to establish her pharmaceutical business. To accommodate her growing needs, she subleased portions of the upper floor: one to Dr. Rogelio Sangalang in August 1973 for a monthly rental of P300.00, which he used as a dental clinic, and another to Hatanaka in 1974, also at P300.00 monthly, which Hatanaka utilized as her residence. The sublease agreements were temporary, stipulating that Madriaga could reclaim the premises upon notifying the sublessees if she required them for her business. By 1978, Madriaga's business had flourished, prompting her to renew her lease and terminate the subleases with Sangalang and Hatanaka. While Sangalang complied and vacated, Hatanaka refused to leave. Consequently, Madriaga filed an ejectment action against Hatanaka in the City Court of Manila, which resulted in a dismissal of her complaint by the Metropolitan Trial Court. Upon appeal, the Regional Trial Court reversed this decis...