G.R. No. L-74279 & 74801-03. January 20, 1988. MAXIMO ROXAS, ANGEL MANTES and ARTURO DEL PRADO, petitioners, vs. INTERMEDIATE APPELLATE COURT, CELESTINO PERNES, PAULINO TALLE (deceased) represented by ROSANNA TALLE, SPOUSES ANTONIO and HERMELINA GUEVARRA, NONILON ALPUERTO, CIPRIANO FRANCISCO and FORTUNATA PIALAN, respondents.
FACTS

Petitioners Maximo Roxas, Angel Mantes, and Arturo Del Prado filed ejectment complaints in August 1980 against private respondents before the Municipal Court of San Juan, Rizal. They alleged that since February 1975, respondents had been occupying their properties and refused to vacate despite a 90-day notice, as petitioners needed the premises for their own use or for their immediate family. They sought respondents’ ejectment, payment of attorney’s fees, and reasonable rentals. Respondents, in turn, filed a complaint for consignation/specific performance, offering to pay rentals at a minimal rate. After procedural challenges, the Metropolitan Trial Court ruled in favor of petitioners, ordering respondents to vacate, pay reasonable compensation for use, and pay attorney’s fees. The Regional Trial Court affirmed this decision in toto.
The subject lots were originally owned by Saint Rita’s College, to whom respondents paid rent as lessees. The property was subsequently sold to B.F. Goodrich, Inc. in 1972, then to Roxanne Salem in 1975 due to the Parity Act, and finally to the petitioners. Only petitioner Roxas, among the occupants, was able to purchase a portion. Upon subdivision, he discovered respondents Talle and Pernes occupied part of his purchased lot. Petitioners demanded respondents vacate for personal use.

ISSUE

Whether the Intermediate Appellate Court erred in reversing the lower courts and dismissing the ejectment complaints, thereby denying petitioners’ right to recover possession of their properties for personal use.

RULING

The Supreme Court granted the petition, reversed the IAC decision, and reinstated the RTC judgment. The legal logic centered on the correct application of tenancy laws and the paramount right of an owner to recover property for personal use. The IAC erroneously applied Batas Pambansa Blg. 25, which governed ejectment grounds, by ruling that the sale of the property to petitioners precluded ejectment. The Supreme Court clarified that the law’s exclusion of “sale of the leased property” as a ground for ejectment applies prospectively to sales occurring after its effectivity, not to sales consummated years prior, as in this case where the sale to petitioners occurred in 1975.
Crucially, the Court emphasized that the owner’s need for the property for personal use or for an immediate family member is a compelling statutory ground for ejectment under BP 25. This right is not extinguished by the mere continuity of possession by tenants through successive ownership changes. The Court found petitioners’ need genuine and paramount. Furthermore, it noted that during litigation, respondents had subleased portions without consent, constituting an independent ground for ejectment. While the state policy assists tenants, it cannot oppress landowners by denying them the use of their own property when a legitimate personal need exists. The scales of justice must equitably balance tenant protection with the fundamental property rights of owners.