Title
Alburo vs. Villanueva
Case
G.R. No. L-3003
Decision Date
Jan 2, 1907
Plaintiff seeks possession of inherited land after rental term expires; defendant claims reimbursement for improvements and contract renewal, but court denies both, allowing only removal of constructed house.
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Case Digest (G.R. No. L-3003)

Facts:

  1. Ownership and Rental Agreement:

    • The plaintiff, Lorenza Alburo, inherited a lot of land in Manila from her grandfather.
    • On January 23, 1892, the lot was rented to Antonio Susano Goenco under a written contract for a term of six years, with a privilege of renewal for a second six-year term.
    • The defendant, Catalina Villanueva (Goenco's wife), took possession of the lot under this rental agreement.
  2. Improvements Made by the Defendant:

    • The defendant and her husband spent a considerable sum filling in and leveling the lot.
    • They also constructed a house made of hard materials on the lot.
    • The rental contract allowed the tenant to build on the lot but was silent on the disposition of the house or improvements after the rental term expired.
  3. Dispute Over Possession:

    • At the expiration of the rental term, the defendant refused to surrender the lot.
    • The plaintiff filed an action to recover possession of the lot.
    • The trial court ruled in favor of the plaintiff, allowing the defendant to remove the house but denying her claims for reimbursement or renewal of the rental contract.
  4. Defendant’s Claims:

    • The defendant sought a third six-year renewal of the rental contract.
    • Alternatively, she claimed reimbursement for the expenses incurred in filling and leveling the lot.
    • She also invoked Article 361 of the Civil Code, which allows a builder in good faith to seek indemnification for improvements made on land.

Issue:

  1. Whether the defendant is entitled to a third six-year renewal of the rental contract.
  2. Whether the defendant is entitled to reimbursement for the expenses incurred in filling and leveling the lot.
  3. Whether the defendant is entitled to the benefits of Article 361 of the Civil Code regarding improvements made on the land.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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