Syjuco

vs. Court of Appeals [G.R. No. 80800. April 12, 1989.]

Facts: The petitioner Pilipinas Bank leased from the private respondents 1,387 (should be, 1,384) square
meters of land commencing from January 1, 1963 and ending on December 31, 1983 as per written
contract.

Paragraph 6 of the Contract of Lease allows the petitioner, as lessee, to 'sublease any part or portion of
the premises or the whole portion thereof without obtaining the consent of the lessors thereto.

The petitioner subleased to Eugenio Trinidad with a term that is coterminous with the original lease
contract. Sections 3 and 6 of the Contract of Sublease prohibited the sublessee Eugenio Trinidad from
further subleasing the property subleased to him by the petitioner. Inspite of the prohibition to sublease
and in violation thereof, Eugenio Trinidad 'constructed stalls/stores thereon and leased the same to 12
persons who conducted their individual business.

Six months after the expiration of the lease and five months after the filing of the complaint for unlawful
detainer, defendant bank surrendered the premises it occupied by surrendering to the court the key to
the bank structure. MeTC rendered judgment for the private respondents. The RTC modified the MTC
decision.

Issue: Whether or not the syjucos has claim of right to possess the premises.

Held: YES. The present occupants did occupy the premises in question in their own capacity. They
cannot be said to have a claim of right springing from the Pilipinas Bank as original lessee because the
lease agreement between Mr. Trinidad and the present occupants is null and void, it being contrary to
the contract of sub-lease. Likewise, the said contract of sub-lease having been automatically ended
when Mr. Trinidad further sub-leased the premises to the occupants, no true claim of right to possess
the said premises may be ascribed to said occupants as emanating from Pilipinas Bank. As such, the
latter cannot be considered the proper party to oust said occupants within the meaning of Section 1,
Rule 70 of the Rules of Court.

WHEELERS CLUB INTERNATIONAL, INC vs JOVITO BONIFACIO, JR. [G.R. No. 139540. June 29, 2005.]

Facts: Rosario, Romeo, Virgilio, Generoso, Andres, Jovito, Jose (all surnamed Bonifacio), Zenaida B. La
guera, Corazon B. Calub, and Ma. Cristina B. De Guzman are the registered co-owners of a parcel of land
with improvement situated at No. 83 EDSA, Mandaluyong City. The co-owners comprised the Board of
Directors of J & R Bonifacio Development Corporation ("JRBDC").

Bonifacio Development Associates, Inc. ("BDAI") entered into a Contract of Lease with Wheelers for a
term of five years.

JRBDC entered into a Lease Development Agreement with BDAI. Under the Lease Development
Agreement, BDAI was authorized to renovate, manage, develop, and sublease the Property. The term of
the agreement was also for five years.

The co-owners demanded that BDAI submit accounting records of all income from the Property.

BDAI, in turn, demanded that the co-owners furnish it with receipts and records of cash and check
advances.
The co-owners approved a Resolution terminating the authority of "Jaime C. Bonifacio" to manage and
administer the Property for BDAI's failure to submit an accounting of the income from the Property.

Rosario Bonifacio ("Rosario"), as President and Chairman of the Board of JRBDC, wrote Jaime, as
President and Chairman of BDAI, a letter terminating the "agreement with JRBDC" for non-payment of
whatever was due to JRBDC under the agreement.

the co-owners approved a Resolution appointing Jovito as the new administrator of the Property.

BDAI insisted that there was no valid reason for the termination of BDAI or Jaime's management of the
Property.

Jovito wrote to Wheelers claiming that the co-owners did not authorize the Contract of Lease between
BDAI and Wheelers. Jovito gave Wheelers ten days to vacate the Property.

Meanwhile, Wheelers continued to pay BDAI the monthly rentals from February to September 1997.

Jovito, as a co-owner of the Property, filed with the MTC a complaint for unlawful detainer against
Wheelers.

This petition for review assails the Decision of the Court of which dismissed the petition of Wheelers
questioning the Decision of the Regional Trial Court. The RTC Decision reversed on appeal the Decision
of the Metropolitan Trial Court which dismissed the complaint for unlawful detainer of respondent
Jovito Bonifacio, Jr. ("Jovito") against Wheelers.

SHORTER VERSION

FACTS: This petition for review assails the Decision of the Court of which dismissed the petition of
Wheelers Club International, Inc. ("Wheelers") questioning the Decision of the Regional Trial Court. The
RTC Decision reversed on appeal the Decision of the Metropolitan Trial Court which dismissed the
complaint for unlawful detainer of respondent Jovito Bonifacio, Jr. ("Jovito") against Wheelers.
In his complaint for unlawful detainer, Jovito claimed that Wheelers disregarded its obligation to pay
rentals to the co-owners from February to October 1997. However, Wheelers' obligation to pay the
rentals arose from its Contract of Lease with BDAI. Wheelers did not have a separate lease agreement
with Jovito or the other co-owners. Wheelers' continued possession of the Property was by virtue of the
Contract of Lease it executed with BDAI.

Issue: Whether or not the co-owners have a cause of action for unlawful detainer against wheelers for
non-payment of rentals and expiration of the term of the lease agreement.

Held: NO. BDAI is the sub-lessor of the Property. BDAI's sub-lease agreement with Wheelers is within
the five-year term of BDAI's principal lease with the co-owners. Until the expiration of the five-year term
of BDAI's principal lease, the sub-lease agreement between BDAI and Wheeler remains valid, unless the
sub-lease agreement is judicially annulled in the proper case, or unless there is a judgment cancelling
BDAI's principal lease with the co-owners or ousting BDAI from the Property.Moreover, no lease
agreement exists between the co-owners and Wheelers. The Contract of Lease between BDAI and
Wheelers was still valid and subsisting when Jovito filed the unlawful detainer case. Thus, at the time of
filing of the unlawful detainer complaint, Jovito and the other co- owners did not have a cause of action
to eject Wheelers from the Property.

TAMIO vs Ticson [G.R. No. 154895. November 18, 2004.]


Facts: "The Roman Catholic Archbishop of Manila (RCAM) is the owner of an apartment unit originally
leased to Mr. Fernando Lopez Lim.

After the demise of Mr. Fernando Lim, [his] children became the occupants thereof. One of [them,
Valentine Lim] requested respondent Encarnacion Ticson, for financial assistance [in order] to purchase
the apartment unit from RCAM. In exchange, Valentine Lim executed a waiver in favor of respondent.
respondent executed a contract of lease [in favor of petitioner], on the basis of the waiver from
Valentine Lim respecting the apartment unit, for a period of three (3) months.

"Meanwhile, after the expiration of the three (3) month lease, respondent demanded petitioner to
vacate the premises for the use of the former's family members. Petitioner failed to comply, giving rise
to the instant case for unlawful detainer.

The MTC ordered the dismissal of the complaint for unlawful detainer.

Meanwhile, petitioner entered into a Contract of Lease over the same property with RCAM for a term of
one year.

The CA agreed with the RTC that respondent must have acquired legal possession over the apartment
unit as an assignee thereof, considering the waiver/assignment executed in her favor by the previous
lessees.

Hence, this petition.

Issue: Whether or not respondent is entitled to Rental Arrearages.

Held: YES. In general, a lessee is not allowed to challenge the title of the lessor. Indeed, it is immaterial
whether the lessor had any title at all to the property at the time the lease was commenced. However,
due to the peculiar circumstances in the present case, the Court makes an exception to this rule.
Otherwise, it would sanction unjust enrichment in favor of the respondent and cause unjust poverty to
the petitioner.

Coca-Cola Bottlers Philippines, Inc. v. Court of Appeals [G.R. No. 100957. January 27, 1994.]

Facts: A contract of lease was executed between private respondent Cesar B. Bautista as lessors and
petitioner Coca-Cola Bottlers Philippines, Inc. as lessee for a period of ten (10) years from October 1,
1982 to September 30, 1992, renewable for a five-year term subject to the mutual agreement of the
parties.

Sometime in December 1983, private respondents received a letter from Coca-Cola informing it of the
company's intention to terminate the lease agreement. Private respondents wrote Coca-Cola that its
proposal of terminating the contract was not acceptable.

For failure of Coca-Cola to pay the rentals on the leased property after December 1983, the Private
respondents filed a complaint against it with the lower court for specific performance and damages.

The trial court ordered Coca-Cola to pay back rentals plus interest.

The Court of Appeals affirmed the Regional Trial Court's decision. Petitioner filed a Motion for
Reconsideration but the same was denied in a resolution by the Court of Appeals.

Hence, this petition.

Petitioner contends that as lessee, it had been denied its rights to the enjoyment or use of the thing
leased under Art. 1543 of the Civil Code, thereby unjustly exempting respondents from their obligation
to render the same fit for the use intended.

Issue: Whether or not petitioner was justified in pre-terminating the contract of lease.

Held: NO. It was clearly the intention of the parties, upon entering into the contract of lease, for
petitioner to simply obtain a site, "a flat surface," for the establishment of a Malabon sales office. This
was understood and agreed upon by private respondents. Thus, in accordance with the said contract,
petitioner constructed on the subject land its sales o ce, warehouse, water tank and gasoline tank.
Under these circumstances, private respondents were under no obligation to make the necessary
repairs in order to keep the land suitable for the purpose for which it had been intended.

Bercero v. Capitol Development Corp. [G.R. No. 154765. March 29, 2007.]

Facts: Respondent Capitol Development Corporation leased its commercial building and lot located at
1194 EDSA, Quezon City to R.C. Nicolas Merchandising, Inc., (R.C. Nicolas) for a 10-year period with the
option for the latter to make additional improvements in the property to suit its business and to
sublease portions thereof to third parties.

R.C. Nicolas subleased separate portions thereof to petitioner Pedro T. Bercero. Petitioner's sublease
contract with R.C. Nicolas was for a three-year period.

Meanwhile, for failure to pay rent, respondent filed an ejectment case against R.C. Nicolas before the
Metropolitan Trial Court. Respondent also impleaded the sub-lessees of R.C. Nicolas as parties-
defendants.

During the pendency of the case, petitioner entered into a compromise settlement with respondent. In
the compromise settlement, the sub-lessees recognized respondent as the lawful and absolute owner of
the property and that the contract between respondent and R.C. Nicolas had been lawfully terminated
because of the latter's non-payment of rent; and that the sub-lessees voluntarily surrendered
possession of the premises to respondent; that the sub-lessees directly executed lease contracts with
respondent considering the termination of leasehold rights of R.C. Nicolas.

Petitioner entered into a lease contract with respondent for a three-year period.

Issue: Whether or not the lease contract entered into between petitioner and respondent, during the
pendency of the lease contract with R.C. Nicolas, is void.

Held: YES. Respondent's unilateral rescission of its lease contract with R.C. Nicolas, without waiting for
the final outcome of the ejectment case it filed against the latter, is unlawful. A lease is a reciprocal
contract and its continuance, effectivity or fulfillment cannot be made to depend exclusively upon the
free and uncontrolled choice of just one party to a lease contract.

Thus, the lease contract entered into between petitioner and respondent, during the pendency of the
lease contract with R.C. Nicolas, is void.

Madamba v. Araneta, G.R. No. L-12017, [August 28, 1959]

Facts: Madamba filed with the Bureau of Lands Application No. 2788, for a lease contract on an
agricultural public land, situated in the barrio of Patanad, municipality of Echague, province of Isabela.

The contract of lease was awarded to Madamba. However, owing to delinquency in the payment of the
stipulated rentals, beginning from the year 1945, said contract was cancelled by respondent Salvador
Araneta, as Secretary of Agriculture and Natural Resources.

Three motions for reconsideration, filed by Madamba, were denied.

Hence, Madamba filed this petition against said officials, as well as against sixteen (16) other persons
named in the petition, who, allegedly, had taken possession of portions of the above-mentioned
property, thru force and intimidation.

Issue: Whether or not the lessor is liable for the disturbance in possession of lessee.

Held: NO. the disturbance in plaintiff's possession, with respect to small portions of the leased property,
was admittedly caused by mere intruders, who acted without any color of title or right.

Where the disturbance in the lessee's possession was caused by mere intruders who acted without any
color of title or right, the distrubance was a mere act of trespass for which the lessor shall not be liable.
However, the lessee shall have a direct action against the trespass.

LL & Company Development & Agro-Industrial Corp. v. Huang Chao Chun, G.R. No. 142378, [March 7,
2002]

Facts: Respondents entered into a contract of lease with petitioner for a period of five (5) years with an
option to renew and giving respondents, at their expense, the right to introduce improvements which
shall become the property of petitioner-lessor at the expiration of the contract.
Respondents constructed a building worth P24,000,000.00. After the contract expired, petitioner
demanded that respondents vacate the premises. The latter refused, claiming that the contract was
automatically renewed, thus the filing of an unlawful detainer suit by petitioner against respondents.
The MTC rendered judgment in favor of respondents holding that the contract entered into may be
extended for reasons of justice and equity.
The RTC affirmed the decision of the lower court, dismissed the unlawful detainer case, and further ruled
that the lessees could unilaterally renew the contract for another five (5) years.
This was affirmed by the Court of Appeals, hence, the present recourse.

Issue: Whether or not the court could still extend the term of the lease, after its expiration.

Held: NO. It was held that the extension of a lease contract must be made before the term of the
agreement expires. After the lapse of the stipulated period, the courts cannot belately extend or make a
new lease for the parties; that an "option to renew" is reciprocal requiring the consent of both the lessor
and the lessee; and that the parties are free to enter into contract and that courts cannot rescue the
parties from the necessary consequences of their acts.




















Arevalo Gomez Corp. v. Lao Hian Liong, G.R. No. 70360, [March 11, 1987]

Facts: The petitioner executed a "Contract of Lease" covering the petitioner's property at Magsaysay
Avenue, Baguio City, for a term of fifteen years.

Prior to the expiration of the lease and for some time thereafter, the parties entered into negotiations
to fix a new rental but could not come to any agreement. In the end, the petitioner served on the
respondent a written notice to vacate the leased premises in view of the termination of their contract.
When the respondent refused to comply, the petitioner filed a complaint for ejectment against him in
the City Court of Baguio City.

Applying Article 1670 of Civil Code, the trial court held in favor of the defendant.

Issue: Whether or not there was an implied renewal?

Held: NO. Where the lessor is unwilling in any event to renew the lease for whatever reason, it will be
necessary for him to serve on the lessee a formal notice to vacate. As no talks have been held between
the lessor and the lessee concerning the renewal of the lease, there can be no inference that the
former, by his inaction, intends to discontinue it. In such a case, no less than an express notice to vacate
must be made within the statutory 15-day period.

Applying these principles, the Court holds that the lease was not impliedly renewed in the instant case.

Torres v. Court of Appeals, G.R. No. 92540, [December 11, 1992]

Facts: Petitioner spouses Aniano and Josefina Torres and private respondent Adela B. Flores entered
into a contract of lease related to ten parcels of land belonging to the latter. Private respondent leased
to the petitioner for a specified term of four agricultural years commencing from 1985 and at stipulated

rentals payable in piculs of sugar.

Before the expiration of these contracts, the parties agreed on their renewal under the original terms,
subject to the condition that the lessees would deliver to Flores the amount of P50,000.00 not later than
February 15, 1989.

Flores claims that the petitioners failed to comply with this condition and that consequently she
informed them that she was taking over her property upon the expiration of the contracts. She
reiterated this notice a month later and advised them not to undertake any new cultivation on the
lands. When her subsequent demands for the surrender of her property were disregarded, she sued the
petitioners for illegal detainer.

The petitioners submitted that the contracts had been validly renewed because they had complied with
the above-mentioned condition.

After trial under the Rule on Summary Procedure, it was held that the contracts had not been validly
renewed because the Torreses had failed to deliver the amount of P50,000.00 in cash to Flores as
promised.

This finding was affirmed on appeal to the Regional Trial Court of Dumaguete City. The Court of Appeals
sustained the findings of the lower courts that the contracts had not been validly renewed. The
petitioners' motion for reconsideration was denied.

Issue: whether or not the original contracts of lease entered into between the petitioners and the
private respondent have been validly renewed.

Held: NO. The facts of this case as found by the lower courts clearly show that there was no implied
renewal but instead an express termination of the contracts of lease. This is evident from the letters of
Flores to the petitioners advising them that she would take over her property upon the end of
agricultural year 1989 and that they should not undertake any new cultivation of the leased lands and
demanding again that they vacate the same.