Sps. Arturo Lipata v. Honorable Court of Appeals

Summary

This Supreme Court case involves an ejectment dispute where property buyers sought to evict existing lessees for personal use. The Estrada spouses purchased leased premises from the Yupangcos in 1978, with the Lipata and Tiquia couples as tenants. Estrada demanded vacation citing family housing needs, stopped collecting rent, and filed ejectment proceedings in 1980. The case progressed through all court levels, with each affirming Estrada's right to eject the tenants. The Supreme Court held that under Section 5(c) of BP 25, all requisites for ejectment based on owner's personal need were satisfied: genuine need, no alternative housing, expired lease period (month-to-month under Article 1687), and proper notice. The Court applied humanitarian exemption principles and found the lease properly terminated. The decision established that unrecorded leases without definite periods can be terminated by purchasers with knowledge of the lease, subject to Civil Code provisions and proper demand procedures.