G.R. No. 88632 - Garcia vs. Court of Appeals

The governing statute for ejectment at the time of the case was B.P. Blg. 25, which outlined specific grounds for judicial ejectment.
Section 5(c) allows for ejectment if the lessor needs the property for personal use, provided that:
- The lease period has expired.
- The lessor gives a three-month notice to vacate.
- The lessor or an immediate family member occupies the unit for at least one year.
Section 5(f) states that the expiration of a written lease contract is a separate ground for ejectment, independent of the notice requirement in Section 5(c).

The private respondent contested only the compliance with the three-month notice requirement.
The expiration of the lease period under Section 5(f) provides a legal ground for ejectment regardless of the lessor's reason for repossession.
The lease in question, although not specifying a definite term, was understood to terminate when the lessor needed the premises.
The private respondent had signed a written promise to vacate within three months of being notified, which effectively amended the lease contract.

The Court of Appeals incorrectly ruled that the petitioner needed to provide a new three-month notice since he was not a party to the original lease.
The petitioner inherited all rights from his predecessor-in-interest, who had already provided the required notice.
The right to eject the private respondent transferred to the petitioner upon purchasing the property, negating the need for a new notice.

The Court of Appeals erroneously concluded that the Municipal Trial Court (MTC) lacked jurisdiction over the ejectment case.
The MTC's jurisdiction is determined by the nature of the complaint, which was solely about the right to eject based on the lease's expiration and repeated demands to vacate.
The petitioner needed the property for personal use, while the private respondent continued to occupy it despite multiple demands to leave.

The petitioner purchased a parcel of land previously leased to the private respondent, who had constructed a house on the property.
The private respondent had promised to vacate the premises within ninety days of a notice given on November 19, 1978, but failed to do so.
After repeated demands for compliance, the petitioner filed an ejectment suit in the MTC, which ruled in favor of the petitioner.

The Court of Appeals ruled that the petitioner did not provide the required notice and set aside the MTC's decision.
The petitioner argued that the private respondent's continued...continue reading