G.R. No. L-65102 September 28, 1984
MAXIMO AQUINO, petitioner, vs. INTERMEDIATE APPELLATE COURT, PEDRO PERALTA and LOLITA PERALTA, respondents.

FACTS

Petitioner Maximo Aquino owned a lot at 19th Avenue, Cubao, Quezon City. A 50-square-meter portion was leased to Maximo Siobal, but the parties and lower courts treated the lease as held by Exequiel Peralta, who built a house on it. Exequiel sold the house to his nephew, respondent Pedro Peralta. The lease expired in 1975, but upon the wife’s pleading, Aquino extended it until February 18, 1976. After expiration, Aquino demanded that the Peraltas vacate so he could construct a five-door apartment for his married children. Upon their refusal, Aquino filed an ejectment suit in 1980.
The city court and the Regional Trial Court ordered ejectment, finding it justified under Batas Pambansa Blg. 25. The Intermediate Appellate Court reversed, applying the Urban Land Reform Law (Presidential Decree No. 1517). It held that the Peraltas, as legitimate tenants who resided for over ten years and built a home, were protected from dispossession under Section 6 of the decree, which grants security of tenure and a right of first refusal in urban land reform zones.

ISSUE

Whether the Urban Land Reform Law bars the ejectment of the Peralta spouses from the subject lot.

RULING

No, the Urban Land Reform Law does not apply. The Supreme Court reversed the Appellate Court, affirming the lower courts’ ejectment orders. The legal logic is twofold. First, the property’s location is determinative. For the law’s protections to apply, the land must be within a declared urban land reform zone or Area for Priority Development (APD). The lot on 19th Avenue, Cubao, is not among the sixty-six blighted APDs enumerated in Proclamation No. 1967. The proclamation lists “5th to 7th Avenue” but not 19th Avenue, thus excluding the subject property from the law’s coverage.
Second, the Peraltas’ status as legitimate tenants under the law is questionable. The protective mantle of Section 6 requires legitimate tenancy established by a legal contract of continuous occupancy for at least ten years. The facts reveal a tenuous chain of possession originating from a written lease with Siobal, not the Peraltas. Their occupancy, derived from a subsequent sale of a house, lacks the contractual privity with the owner required to qualify as the “legitimate tenants” contemplated by the decree. Therefore, the Peraltas cannot invoke the law’s security of tenure provisions. The ejectment is valid, and Aquino is entitled to recover possession of his property.