Scribd Logo
Upload

Welcome to Scribd!

  • 177 views

    Estanislao Vs Gudito

    Uploaded by

    H
    This case involves a dispute over possession of a residential lot between the Spouses Estanislao, who had been leasing and occupying the lot since 1934, and the current owners, the Spouses Gudito. While the Estanislaos argued they could not be evicted under a land reform law, the Court ruled in favor of the Guditos, finding that the Guditos had established ownership of the property and that the land reform law's right of first refusal did not apply because the Guditos were not selling the property but seeking to use it for their own residential purposes. The Court affirmed the eviction of the Estanislaos.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Estanislao Vs Gudito

    Uploaded by

    H
    177 views2 pages
    This case involves a dispute over possession of a residential lot between the Spouses Estanislao, who had been leasing and occupying the lot since 1934, and the current owners, the Spouses Gudito. While the Estanislaos argued they could not be evicted under a land reform law, the Court ruled in favor of the Guditos, finding that the Guditos had established ownership of the property and that the land reform law's right of first refusal did not apply because the Guditos were not selling the property but seeking to use it for their own residential purposes. The Court affirmed the eviction of the Estanislaos.

    Original Description:

    Case Digest: Lease

    Original Title

    Estanislao vs Gudito

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This case involves a dispute over possession of a residential lot between the Spouses Estanislao, who had been leasing and occupying the lot since 1934, and the current owners, the Spouses Gudito. While the Estanislaos argued they could not be evicted under a land reform law, the Court ruled in favor of the Guditos, finding that the Guditos had established ownership of the property and that the land reform law's right of first refusal did not apply because the Guditos were not selling the property but seeking to use it for their own residential purposes. The Court affirmed the eviction of the Estanislaos.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    177 views2 pages

    Estanislao Vs Gudito

    Uploaded by

    H
    This case involves a dispute over possession of a residential lot between the Spouses Estanislao, who had been leasing and occupying the lot since 1934, and the current owners, the Spouses Gudito. While the Estanislaos argued they could not be evicted under a land reform law, the Court ruled in favor of the Guditos, finding that the Guditos had established ownership of the property and that the land reform law's right of first refusal did not apply because the Guditos were not selling the property but seeking to use it for their own residential purposes. The Court affirmed the eviction of the Estanislaos.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    PURIFICACION ESTANISLAO and RUPERTO ESTANISLAO vs.

    SPOUSES NORMA GUDITO and


    DAMIANO GUDITO
    G.R. No. 173166; March 13, 2013
    PERALTA, J.:

    Facts:
    The Spouses Gudito are the owners of a residential lot being leased by the Spouses Estanislao
    on a month-to-month basis. The Estanislaos had been renting and occupying the subject lot
    since 1934 and were the ones who built the house on the subject lot in accordance with their
    lease agreement with one Gaspar Vasquez. When Gaspar Vasquez died, the portion of the lot
    on which the Estanislaos house was erected was inherited by his son Victorino Vasquez,
    married to Ester Vasquez (Vasquez couple).

    In the 1980s, the Vasquez couple wanted the Estanislao family and the other tenants to vacate
    the said property, but the tenants refused because of laws allegedly prohibiting their ejectment
    therefrom. Resultantly, the Vasquez couple refused to accept their rental payments. Thus,
    Purificacion Estanislao, with due notice to Ester Vasquez, deposited the amount of her monthly
    rentals at Allied Banking Corporation under a savings account in the name of Ester Vasquez as
    lessor.

    In the interim, a Deed of Donation was executed by the Vasquez couple in favor of Norma
    Vasquez Gudito. Subsequently, the Estanislaos were notified to remove their house and vacate
    the premises within three months because of their urgent need of the residential lot. However,
    the Estanislaos failed to comply.

    Accordinglythe Guditos filed a Complaint for Unlawful Detainer/Ejectment against the


    Estanislaos before the MeTC of Manila who rendered a Decision in favor of the former and
    ordered the latter to pay reasonable compensation for the use and occupancy of the subject
    premises in the amount of P500.00 a month beginning October 1985 and every month
    thereafter until they shall have finally and actually vacated the subject premises.

    On appeal, the RTC reversed the MTCs Decision and enjoined the "Guditos" to respect the
    lease agreement as well as the possession of the "Estanislaos" over the leased premise and
    should the former decide to sell or otherwise dispose of the same property to third parties, the
    latter are given the right of first refusal pursuant to PDs 1517 and 2018.

    The CA, however, reinstated the Decision of the MTC. Hence, this petition.

    Issues:
    1. Does PD 1517 preclude the eviction of the Spouses Estanislao from the subject
    property?
    2. Are the Spouses Estanislao entitled to the right of first refusal?
    Held:
    1. The Guditos have overwhelmingly established their right of possession by virtue of the
    Deed of Donation made in their favor. This Court is not persuaded with the Estanislaos
    insistence that they cannot be evicted in view of Section 6 of P.D. 1517, which states
    SECTION 6. Land Tenancy in Urban Land Reform Areas. Within the Urban Zones
    legitimate tenants who have resided on the land for ten years or more who have built
    their homes on the land and residents who have legally occupied the lands by contract,
    continuously for the last ten years shall not be dispossessed of the land and shall be
    allowed the right of first refusal to purchase the same within a reasonable time and at
    reasonable prices, under terms and conditions to be determined by the Urban Zone
    Expropriation and Land Management Committee created by Section 8 of this Decree.

    As can be gleaned from the foregoing, the Estanislaos cannot use P.D. 1517 as a shield
    to deny the Guditos of their inherent right to possess the subject property.

    2. The CA correctly opined that "under P.D. 1517, in relation to P.D. 2016, the lessee is
    given the right of first refusal over the land they have leased and occupied for more
    than ten yean and on which they constructed their houses. But the right of first refusal
    applies only to a case where the owner of the property intends to sell it to a third party.
    If the owner of the leased premises do not intend to sell the property in question but
    seeks to eject the tenant on the ground that the former needs the premises for
    residential purposes, the tenant cannot invoke the land reform law." Clearly, the
    circumstances required for the application of P.D. 1517 are lacking in this case, since the
    Guditos had no intention of selling the subject property to third parties, but seek the
    eviction of the Estanislaos on the valid ground that they need the property for
    residential purposes.

    You might also like