Title
Agalo-os vs. Intermediate Appellate Court
Case
G.R. No. L-67220
Decision Date
May 7, 1987
The court ruled in favor of the Development Bank of the Philippines, affirming that the expired lease agreement did not imply renewal, rendering the brothers' claims of illegal possession unfounded.
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Case Digest (G.R. No. L-67220)

Facts:

  • Ilvino Agalo-os and Gregorio Agalo-os are the plaintiffs-appellants.
  • Respondents-appellees include the Intermediate Appellate Court, the Development Bank of the Philippines (DBP), and Julio Geroche.
  • Consuelo Gonzales Agalo-os, the predecessor of the petitioners, was granted leasehold rights over a public land fishpond (Lot No. 2-1360 pt.) in Escalante, Negros Occidental.
  • The lease was formalized under Fishpond Lease Application No. 719, which expired on December 31, 1965.
  • Vicente and Consuelo Agalo-os secured a loan of P20,000.00 from the Rehabilitation Finance Corporation (now DBP) on November 11, 1955, to be repaid by August 23, 1965, with a 6% interest rate.
  • The loan was documented through a promissory note, secured by an assignment of the leasehold rights, approved by the Secretary of Agriculture and Natural Resources.
  • DBP deferred its right to take possession despite the loan maturing without payment.
  • After the deaths of Vicente and Consuelo Agalo-os, Ilvino Agalo-os entered into a "Supplemental Agreement" with Julio Geroche on November 4, 1966, leasing the fishpond for ten years at an annual rental of P4,500.00, payable to DBP.
  • Payments made by Geroche were insufficient to cover the outstanding obligation.
  • On March 2, 1972, DBP took possession of the fishpond based on the assignment of leasehold rights.
  • The petitioners filed a complaint against DBP and Geroche for reformation of the instrument and damages on May 23, 1972.
  • The lower court dismissed the complaint, ruling that the lease had expired and that there was no cause of action.
  • The Intermediate Appellate Court affirmed this decision, prompting the petitioners to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the decision of the Intermediate Appellate Court.
  • The Court ruled that the leasehold rights had expired on December 31, 1965, and that the petitioners had no cause of action against the respondents.
  • The Court upheld the lower court's finding that the ...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the factual findings that the leasehold rights had expired, as acknowledged by both parties in their stipulation of facts.
  • The expiration of Fishpond Lease...continue reading

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