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- Implied New Lease (Buce vs. Sps. Galeon, G.R. No. 222785, March 2, 2020) | May 9, 2025
Implied New Lease (Buce vs. Sps. Galeon, G.R. No. 222785, March 2, 2020) | May 9, 2025
In the above-entitled case, the Supreme Court discussed the elements of implied new lease under Article 1670 of the New Civil Code of the Philippines.
In the above-entitled case, the Supreme Court discussed the elements of an implied new lease under Article 1670 of the New Civil Code of the Philippines, to wit:
(a) the term of the original contract of lease has expired;
(b) the lessor has not given the lessee a notice to vacate; and
(c) the lessee continued enjoying the thing leased for 15 days with the acquiescence of the lessor.

Sometime in 2006, Jeffery, a United States Navy retiree, met Rowena in a bar owner by Rowena’s mother. At that time they started dating, Jeffery knew Rowena had two children from a previous relationship, and Rowena knew Jeffery was married to another, but that his divorce was still pending.
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