Case Summary (G.R. No. 76294)
Background of the Case
- In 1974, Marlene Madriaga (petitioner) subleased a portion of a commercial building to Mila Hatanaka (respondent) for residential use at a monthly rental of P300.00.
- The lease agreement was temporary, stipulating that Hatanaka would vacate the premises upon notice if Madriaga required the space for her business.
- In 1978, Madriaga notified Hatanaka of her need for the premises, but Hatanaka refused to vacate.
Legal Proceedings
- Madriaga filed an ejectment suit against Hatanaka after her refusal to leave.
- The Metropolitan Trial Court dismissed the complaint, but the Regional Trial Court reversed this decision, ordering Hatanaka's eviction.
- Hatanaka appealed to the Court of Appeals, which reversed the Regional Trial Court's ruling, citing Batas Pambansa Bilang 25 as applicable to the case.
Court of Appeals Ruling
- The Court of Appeals held that Batas Pambansa Bilang 25 applied because the premises were used for residential purposes, despite being part of a commercial building.
- The court concluded that since Madriaga did not need the premises for personal use or for her family, Hatanaka could not be evicted.
Supreme Court's Analysis
- The Supreme Court emphasized that the termination of the lease agreement is a valid ground for ejectment.
- It clarified that a month-to-month lease can be terminated at the end of any month, supporting Madriaga's right to reclaim the premises.
- The Court noted that the original agreement between the parties allowed for termination if Madriaga needed the space fo...continue reading