Title
Caudal vs. Court of Appeals
Case Decision Date
G.R. No. 83414 Jul 31, 1989
In the case of Caudal v. Court of Appeals, the court ruled in favor of the landlord,
affirming their right to eject the tenant for legitimate residential purposes, as the
premises were considered an auxiliary part of the landlord's main conjugal
dwelling.
Case Digest (G.R. No. 83414)
Comprehensive
Facts:
In the case of "Tony Caudal vs. Hon. Court of Appeals, Hon. Remegio E. Zari, Presiding
Judge, Regional Trial Court, National Capital Judicial Region, Branch 98, Quezon City,
and Dionisio O. Cu," the petitioner is Tony Caudal and the respondents include the Court
of Appeals, Judge Remegio E. Zari, and Dionisio O. Cu. The case was decided on July 31,
1989, with Chief Justice Fernan as the ponente. Dionisio Cu, his wife, and five children
initially rented an apartment at 269-A D. Tuason, Quezon City, but later moved to 38
Silencio St., Santol, Quezon City, due to the owner's need for the former apartment. Cu
then acquired a parcel of land at 157 E. Garcia, Quezon City, in February 1984, which
included a six-door apartment building. On July 2, 1984, Cu notified Caudal, who was
occupying one of the units, of the termination of the lease and gave him until October
1984 to vacate. Despite this, Caudal refused to leave, prompting Cu to file an ejectment
case in the Metropolitan Trial Court (MTC) of Quezon City. The MTC dismissed Cu's
complaint, but upon appeal, the Regional Trial Court (RTC) of Quezon City reversed the
decision, ruling in favor of Cu. Caudal then filed a petition for review with the Court of
Appeals, which affirmed the RTC's decision. Caudal subsequently brought the case to the
Supreme Court.
Issue:
1. Whether the Court of Appeals erred in interpreting Section 5(c) of Batas Pambansa
Blg. 25 and 877, in relation to Section 2(b) of Batas Pambansa 877, to include the use
of the subject apartment door as a stockroom, office, and quarters for maids and
drivers as a ground for ejectment.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, thereby allowing Cu to
eject Caudal from the premises. The conversion of the subject area into a maid/driver's
quarters and stockroom was deemed to fall within the purview of Section 5(c) of Batas
Pambansa 877 as a legitimate need for residential purposes.
Ratio:
The Court's decision was grounded in the interpretation of the term "residential unit"
under Batas Pambansa 877. The law does not strictly limit the meaning of "residence" to
habitation purposes; it allows for some flexibility, including the use of the residence for
home industries or retail stores, provided it is principally used for dwelling purposes.
The Court noted that a servants' quarter is considered an auxiliary part of a residence.
Cu's plan to merge the apartment units into a conjugal dwelling for his family, including
quarters for maids and drivers, was deemed consistent with the law's definition of a
residential unit. The Court also emphasized that the law does not prevent a new owner
from ejecting a lessee if the premises are needed for the owner's use, as long as the
proper notice is given. Cu's notice to Caudal complied with the three-month advance
notice requirement, and Cu's need for a permanent residence was deemed legitimate.
The Court found that giving preferential right to a tenant over a new owner's need for the
premises would be arbitrary and unreasonable.
