- Petitioner
- Jose L. Rivera
- Respondent
- Maximo Trinidad
- Citation
- G.R. No. 23699
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Street, J.
- Decided
- December 4, 1925
Summary
This unlawful detainer case involved Jose L. Rivera's attempt to eject tenant Maximo Trinidad from a Manila property. Trinidad had occupied the lot since 1918 with original owner Dolores Lanuza's consent, constructing a piano repair shop and paying P30 monthly rent. After a family dispute, Lanuza transferred the property to her nephew Rivera in 1921 to facilitate Trinidad's ejection. The Supreme Court found the transfer colorable but held this irrelevant to Rivera's rights as purchaser. The Court ruled Trinidad was a month-to-month tenant subject to ejection, but entitled to remove his improvements without damaging the property. The decision clarified that unlawful detainer actions by purchasers against holdover tenants fall under procedural law rather than Civil Code provisions governing unregistered lease termination.