Title
De la Cruz vs. Roxas
Case
G.R. No. L-100
Decision Date
Nov 16, 1945
Post-war housing crisis; petitioner, a house guest, sought extension to vacate after tenant left. Court upheld eviction, emphasizing legal agreements over housing shortage.

Case Digest (G.R. No. L-100)
Expanded Legal Reasoning Model

Facts:

  • Background and Agreement
    • On July 15, 1945, Judge Mamerto Roxas ordered the petitioners to vacate the premises at No. 1135 Avenida Rizal, Manila, by October 15, 1945.
    • The vacating order was based on a gentleman’s agreement between the petitioners and respondent Eugenio Quesada, which allowed a three-month period for the petitioners to leave.
    • The agreement was later interpreted by Quesada’s answer as granting a period of three months and six days from the decision rendered on July 9, 1945, whereas petitioners were allegedly to vacate as early as February 15 based on earlier rulings and orders.
  • Petitioners’ Circumstances and Claims
    • Petitioner Agustin Alonzo, who was a house guest of the real tenant Francisco de la Cruz, claimed to have lost his house, belongings, and furniture due to a fire on February 11, 1945.
    • Alonzo argued that he had no alternative residence and requested a three-month extension past October 15 to secure new accommodations for himself and his family.
    • The petition asserted that the execution of the judgment ordering his eviction was premature and that halting it would address the broader housing shortage in Manila.
  • Development of the Execution
    • Despite the agreement and the petitioners’ claims, the period for vacating the premises expired as per the judgment.
    • Judge Roxas, taking into account the lapse of the agreed period, issued the writ of execution ordering the petitioners to leave.
    • Deputy Sheriff Getulio Pantoj de Manila, in his affidavit, noted that on October 22 the upper floor was still occupied by Alonzo and his family, while the basement housed unidentified Chinese merchants.
  • Respondent Quesada’s Position and Justifications
    • Quesada maintained that the execution order was in line with the original gentleman’s agreement.
    • He highlighted that petitioners had ample time (over seven months) after the fire to arrange alternative housing.
    • Quesada asserted he needed the premises—specifically:
      • The basement floor as a display room for his chemical products (aligned with his business operations).
      • The upper floor to accommodate Dr. Joaquin Maranon’s family, whose original residence was destroyed.
    • He argued that granting an extension would undermine the sanctity of voluntary agreements and encourage bad faith or dilatory tactics.
  • Procedural and Evidentiary Aspects
    • The facts stated in Quesada’s answer were not denied by the petitioners.
    • The affidavit of Deputy Sheriff Pantoj served as corroborative evidence of the actual occupancy situation at the premises.
    • The case, thereby, presented both legal and moral considerations regarding adherence to agreements and the responsibilities of parties amid the post-war housing crisis.

Issues:

  • Whether the issuance of the writ of execution by Judge Roxas, enforcing the vacate order based on the gentleman’s agreement, constituted a grave abuse of discretion.
    • Did the petitioner, particularly Alonzo as a mere house guest, have any right to remain after the real tenant had vacated?
    • Can the existing housing shortage provide sufficient grounds to grant an extension to petitioners, despite the lapse of the agreed period?
  • Whether the enforcement of the judgment violated legal principles and moral obligations by breaching the gentleman’s agreement.
    • To what extent does personal dignity and honor—as carried by voluntary promises—factor into judicial decisions?
    • Is it justifiable to delay execution given the hardship of finding new housing in post-war Manila?
  • The propriety of impugning the petitioners’ moral character and intentions.
    • Whether any insinuation that petitioner Alonzo sought to profit from the unknown Chinese merchants’ occupancy was substantiated by positive evidence.
    • The implications of such insinuations on the evaluation of good faith in contractual or gentlemanly agreements.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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