Title
Brown vs. Bank of the Philippine Islands
Case
G.R. No. L-10688
Decision Date
Apr 29, 1957
Lessee sued for damages over alleged malicious detainer case; SC ruled action premature pending resolution of detainer case.
Font Size:

Case Digest (G.R. No. L-10688)

Facts:

  1. Contract of Lease:

    • On October 7, 1947, a lease agreement was executed between William H. Brown (lessee) and several lessors, including the Bank of the Philippine Islands (BPI) as attorney-in-fact for certain co-owners.
    • The leased property included a parcel of land in Manila with the Bataan Theater and other improvements.
    • The lease term was three years, renewable for another three years at the lessors' option, with a monthly rental of P8,000 payable in advance.
    • The lessee was responsible for real estate taxes.
    • The contract stipulated that if the building was completely destroyed by fire, the lessors were not obligated to reconstruct it.
    • Any additional improvements made by the lessee that could not be removed would belong to the lessors upon lease expiration or violation of terms.
  2. Destruction of Bataan Theater:

    • The Bataan Theater was completely destroyed by fire in December 1949.
    • Brown constructed a new building, the Clover Theater, before November 15, 1951.
  3. Detainer Case:

    • On November 13, 1953, the lessors filed a detainer case (Civil Case No. 28957) against Brown in the Manila Municipal Court.
    • The lessors alleged that Brown failed to pay P96,322 in unpaid rentals (January to November 1953) and real estate taxes.
    • They demanded that Brown vacate the property and pay the outstanding amounts, plus P8,000 monthly until vacating, and attorney’s fees.
    • The municipal court ruled in favor of the lessors, and Brown appealed to the Court of First Instance of Manila (Civil Case No. 21291).
  4. Present Action for Damages:

    • While the detainer case was pending, Brown filed the present action (Civil Case No. 25147) against BPI and its president, Santiago Freixas, seeking P600,000 in damages.
    • Brown alleged that the detainer case was maliciously filed, that BPI and Freixas induced the other co-owners to file it, and that they refused to settle amicably.
    • He claimed damages for loss of business standing, mental anguish, and other injuries due to the defendants' alleged wrongful acts.
  5. Motion to Dismiss:

    • The defendants filed a motion to dismiss, arguing that the complaint was premature and did not state a cause of action.
    • The Court of First Instance granted the motion and dismissed the case without costs.

Issue:

  1. Whether the complaint filed by Brown against BPI and Freixas states a valid cause of action.
  2. Whether the action for damages is premature given the pending detainer case.

Ruling:

The Supreme Court affirmed the order of the Court of First Instance dismissing the complaint. The Court held that the action for damages was premature because it directly affected the merits of the pending detainer case. Until the detainer case was finally resolved, Brown could not assert a valid cause of action against BPI and Freixas.

Ratio:

  • (Unlock)

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.