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3 Nava v Yaptinchay - VALCOS the plaintiff, thereby making the plaintiff responsible directly to the

44 O.G. No. 9, p. 3332 | Oct. 21, 1947 owner for obligations arising out of the agreement
Lease  In the contract, the plaintiff’s personality as lessee does not
disappear, the plaintiff does not absolutely transmit his rights and
DOCTRINE: In the contract of sublease, the personality of the lessee obligations to the defendant and the defendant does not have
does not disappear; the lessee does not transmit absolutely his rights any direct action to the owner as lessor.
and obligations to the sub-lessee; and the sub-lessee does not have  Whether the plaintiff had the right to sublease the premises is not
any direct action against the owner of the premises as the lessor, to a proper defense for the defendant not only because the
require the compliance of the obligations contracted with the lessee, defendant is a stranger to the lease contract between the
or vice-versa. Moreover, the alleged assignment of cession could not plaintiff and the owner, but also because the defendant, for
have been held valid in this case, because the owner of the premises being privy of plaintiff, cannot attack the lease collaterally for the
did not give his consent to the substitution of the sub-lessee in lieu of simple reason that the tenant is not permitted to deny the title of
the lessee. his landlord.
 On the issue of the garage, it was clearly shown that when the
FACTS: parties entered into the sublease agreement, the stipulation on
1. Nava was permitted to occupy the property of Sps. Quillen the provision of the garage was not included, it was only placed
located in Taft ave., Pasay for P100 per month as an addendum without any consideration.
2. Mr. Quillen formally leased the house to Nava, for which the latter  Court AFFIRMS the judgment appealed from with costs against
paid the corresponding rent for 3 months, it having been defendant.
understood that Nava can stay there for 1 year
3. Defendant Yaptinchay proposed to buy Nava’s right of
occupancy to the house which was accepted by the latter
4. Their agreement was Yaptinchay will buy Nava’s right to the
actual and physical occupancy of the apartment for a period of
10 months
5. Pursuant to the agreement, the defendant paid the first
installment of P1,600 but failed to satisfy the balance
6. Defendant Yaptinchay alleges that before the expiration of the 3
months, Mr. Quillen objected to his stay in the apartment for he
considered the premises not subject to sublease
7. Defendant also alleges that as a consequence, Mr. Quillen took
over the control of the premises and entered into a separate
agreement with the defendant; and that the failure of the plaintiff
to provide a garage (a handwritten addendum to the contract)
the contract was deemed cancelled

ISSUE: WON the contract entered into by Nava and Yaptinchay was a
sublease | YES

RULING:
 In the agreement, it was provided that all rents to be paid to the
owner within the period of 10 months shall be for the account of

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