Short answer. Possibly, if the lease was never recorded. A purchaser of land under an unrecorded lease may terminate it, unless the deed of sale stipulates otherwise or the buyer knew the lease existed. Registration and the buyer's knowledge are the two things that protect a tenant here.
What the law says
The purchaser of a piece of land which is under a lease that is not recorded in the Registry of Property may terminate the lease, save when there is a stipulation to the contrary in the contract of sale, or when the purchaser knows of the existence of the lease.
Civil Code, Article 1676 — Buyer's Right to Terminate an Unrecorded Lease. Read the full provision →
What the law says
The sale is presumed to be fictitious if at the time the supposed vendee demands the termination of the lease, the sale is not recorded in the Registry of Property.
Civil Code, Article 1676 — Buyer's Right to Terminate an Unrecorded Lease. Read the full provision →
Recording is what makes a lease survive a sale
The rule is stated plainly: the purchaser of a piece of land which is under a lease that is not recorded in the Registry of Property may terminate the lease. A lease annotated on the title binds whoever later buys the land, because the buyer takes with notice of it. A lease that exists only between the parties does not automatically bind a stranger who buys the property, which is the uncomfortable answer for the very large number of Philippine tenants whose leases were never registered and never annotated on anything.
The two exceptions carry most tenants
The right to terminate is lost where there is a stipulation to the contrary in the contract of sale, or where the purchaser knows of the existence of the lease. The second is the practical protection, and it is not a demanding standard. A buyer who inspected the property and found you living in it, who was told about the tenancy during negotiations, or who was collecting or crediting your rent is not a buyer without knowledge. So the first thing worth establishing is what the new owner was told and shown before signing, and whether any of that exists in writing.
The fictitious sale presumption
The article also anticipates the sale invented to get rid of a tenant. If the sale is fictitious for that purpose, the supposed buyer cannot use the right at all, and there is a presumption to enforce it: the sale is presumed to be fictitious if at the time the supposed vendee demands the termination of the lease, the sale is not recorded in the Registry of Property. So a stranger who appears with a deed, demands that you leave, and has not registered the purchase is presumptively not entitled to the remedy being asserted. Ask for the title, not the deed.
Right away is the part that is wrong
Even a purchaser entitled to terminate does not thereby acquire the power to remove you personally. Terminating the lease ends your right to stay; recovering possession from someone who will not leave still runs through a court, and locks, utilities and hired help are not shortcuts. Ask for a certified true copy of the title and check for any annotation of your lease, gather whatever shows the buyer knew of your tenancy before buying, and keep paying rent to whoever is entitled to it, because arrears give a new owner a ground that has nothing to do with this article.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Midway Maritime and Technological Foundation, represented by its Chairman/President PhD in Education, Dr. Sabino M. Manglicmot vs. Marissa E. Castro, et al, G.R. No. 189061, August 6, 2014 — read the decision on LawPhil →
- Felipe Uy vs. The Land Bank of the Philippines, G.R. No. 136100, July 24, 2000 — read the decision on LawPhil →
- Cebu Bionic Builders Supply, Inc. and Lydia Sia vs. Development Bank of the Philippines, et al, G.R. No. 154366, November 17, 2010 — read the decision on LawPhil →
- Hubert Nuñez vs. SLTEAS Phoenix Solutions, Inc, G.R. No. 180542, April 12, 2010 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1673 — Grounds for Judicial Ejectment
- Civil Code, Article 1648 — Recording of Leases