Title
Caudal vs. Court of Appeals
Case
G.R. No. 83414
Decision Date
Jul 31, 1989
Cu, as new owner, lawfully ejected Caudal under B.P. 877 for legitimate residential use, including auxiliary purposes like maid/driver quarters, affirming lower courts' rulings.
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Case Summary (G.R. No. 83414)

Legislative Intent in Statutory Construction

  • Legislative intent must be determined by considering the entire statute rather than isolated clauses.
  • Each part of the statute should be interpreted in the context of the whole to ascertain its meaning.

Definition of "Residential Unit" Under Rental Law

  • The term "residential unit" is not limited to habitation but can include spaces used for home industries or retail, provided they are primarily for dwelling.
  • The law allows for a degree of flexibility in defining residential use, emphasizing that the primary purpose must be dwelling.

Inclusion of Servants' Quarters

  • Servants' quarters are considered an integral part of a residence.
  • Other structures, such as kitchens or washrooms, attached to a dwelling are also included in the definition of a dwelling house.

Comprehensive Nature of a Dwelling House

  • A dwelling house encompasses all buildings and attachments used for family purposes.
  • The law recognizes that a dwelling may consist of multiple structures consolidated under one roof.

Immediate Family Definition

  • The term "immediate members of the family" includes maids and drivers, especially when the owner is relocating to the premises.
  • The context of family use is crucial in determining the legitimacy of the need for the property.

Ejectment Rights of a Vendee

  • A vendee can eject a lessee if the property is needed for personal use by the owner or their family.
  • The law supports the right of a new owner to reclaim possession for their family's use.

Termination of Month-to-Month Lease

  • A verbal month-to-month lease is considered a lease with a definite period, which can be terminated with a 30-day notice.
  • The lease was effectively terminated when the new owner provided notice to the lessee.

Preferential Rights of Tenants vs. New Owners

  • Granting preferential rights to tenants over new owners' n...continue reading

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