Case Digest (G.R. No. 119107) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose V. Lagon v. Court of Appeals and Menandro V. Lapuz, decided March 18, 2005 under G.R. No. 119107, petitioner Jose Lagon purchased two parcels of land in Tacurong, Sultan Kudarat on June 23, 1982, from the intestate estate of Bai Tonina Sepi. Private respondent Menandro Lapuz had leased the same property beginning in 1964, and allegedly renewed his lease in 1974 to build commercial structures, remitting rent to the estate’s administrator after Sepi’s death. Upon learning that petitioner was collecting rentals from tenants in those buildings, respondent filed a complaint for tortious interference before the Regional Trial Court (RTC), alleging that petitioner induced Sepi’s heirs to sell and thereby violated his leasehold rights. Petitioner denied knowledge of any subsisting lease, presented a clerk-of-court certification showing no recorded lease, and counterclaimed for damages after the RTC rendered judgment in favor of respondent, declaring the lease valid, restoring po Case Digest (G.R. No. 119107) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- On June 23, 1982, petitioner Jose V. Lagon purchased two parcels of land in Tacurong, Sultan Kudarat, from the intestate estate of Bai Tonina Sepi.
- Private respondent Menandro V. Lapuz claimed he had leased three parcels from Bai Tonina Sepi beginning in 1964, with a renewal in 1974, and had constructed commercial buildings to cover his rental obligations.
- Procedural History
- In 1982, Lapuz filed a complaint for torts and damages in the Regional Trial Court (RTC) of Sultan Kudarat, alleging that Lagon induced the heirs to sell and unlawfully collected rentals, thereby interfering with his leasehold rights.
- On July 29, 1986, the RTC:
- Declared the 1974 lease valid and binding until October 31, 1984;
- Restored possession of the buildings to Lapuz and awarded rentals (P506,850.56) plus various damages (moral, actual, exemplary, temperate, nominal), attorney’s fees and litigation expenses, all with interest;
- Denied Lagon’s counterclaim for damages.
- Lagon appealed to the Court of Appeals (CA). On January 31, 1995, the CA:
- Affirmed the lease’s authenticity, possession, and rentals award;
- Deleted awards for moral, compensatory, exemplary, temperate, nominal damages, and litigation expenses;
- Reduced attorney’s fees to P30,000;
- Ordered payment of net actual rentals of P178,425 (October 1978–August 1983) less P42,700, with interest.
- Lagon filed a petition for review on questions of: tortious interference under Art. 1314, laches, entitlement to damages and attorney’s fees, and the dismissal of his counterclaim.
Issues:
- Did petitioner Lagon’s purchase of the property constitute tortious interference with Lapuz’s lease under Article 1314 of the Civil Code?
- Did Lagon have knowledge of the existing lease, and if so, did he act with malice or wrongful motive?
- Is Lapuz precluded by laches from recovery?
- Was Lapuz properly awarded actual damages and attorney’s fees?
- Was the dismissal of Lagon’s counterclaim for actual and moral damages correct?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)