G.R. No. L-56135 - Cortez vs. Camilon

Presidential Decree No. 20, amending Republic Act 6359, establishes that rentals for lower-income groups are frozen at their 1972 levels as a measure of social justice.
The Civil Code outlines specific grounds for judicial ejectment, including expiration of the lease period, non-payment of rent, violation of contract conditions, and improper use of the leased property.
Batas Pambansa Blg. 25 specifies grounds for ejectment for tenants with monthly rentals not exceeding P300, including the need for the owner or an immediate family member to repossess the property for personal use.

The Cortez spouses argued that the landlord's need for the apartment for a family member is only valid for fixed-term leases that have expired, not for their month-to-month lease.
This argument was deemed fallacious as the landlord, Recaredo Coronel, had formally terminated the month-to-month lease prior to filing the ejectment suit.
The legitimate ground for ejectment was the landlord's need for the apartment for his daughter, which is permissible under the law.

The Court of First Instance ruled in favor of the landlord, affirming the ejectment based on the need for the apartment for his daughter, Grace Coronel-Valdez.
The court clarified that the argument regarding the expiration of the lease was not applicable since the landlord's demand for vacating the premises was based on a legitimate need rather than the lease's expiration.
The decision emphasized that the provisions of the Civil Code regarding ejectment remain applicable, notwithstanding the specific provisions of Presidential Decree No. 20 and Batas Pambansa Blg. 25.