Title
Mirasol vs. Magsuci
Case
G.R. No. L-17125
Decision Date
Nov 28, 1966
Mirasol, owner of 2/5 land share, sued tenants for unpaid rent and eviction after lease extension by prior owner was deemed invalid. SC ruled in Mirasol's favor, ordering tenants to vacate and pay rent.
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Case Digest (G.R. No. L-17125)

Facts:

Ownership and Sale of the Property

  • The land in dispute is a 2,286 square meter lot in Manduriao, Iloilo City, registered under the names of Jose and Asuncion Miraflores, who owned 2/5 and 3/5 shares, respectively, as Lot No. 2575 of the Cadastral Survey of Iloilo.
  • On June 15, 1955, the heirs of Jose Miraflores (Desiderio, Leticia, and Josefina) sold their 2/5 share to Bernabe Mirasol (plaintiff-appellant) in an absolute sale.
  • On June 16, 1955, the same heirs, acting as devisees and legatees of Asuncion Miraflores, entered into a "contract to sell" her 3/5 share to Mirasol, contingent on the probate of Asuncion's will. However, this contract was rescinded on September 15, 1955, due to Mirasol's failure to pay the expenses for the probate proceedings.

Lease Agreements

  • On February 6, 1951, the heirs of Jose Miraflores, through their attorney-in-fact, Jose Mesa, leased their 2/5 share to defendants Antonio Magsuci, Bibiano Laygo, and Crisanta Natal.
  • Only Magsuci's lease was in writing, for three years, renewable for two more years. The lease was extended until February 6, 1956, and later renewed until February 6, 1959.
  • The lease agreements stipulated that the leased portion would be used to build a gasoline station.

Dispute Over Rentals and Ownership

  • On August 9, 1955, Mirasol notified Magsuci that he had purchased the property and demanded that rentals be paid to him. Magsuci refused, claiming no agreement with Mirasol.
  • Similar demands were made to Laygo and Natal, but no records of their responses exist.
  • Mirasol filed an unlawful detainer case against the defendants after they refused to vacate the premises.

Trial Court Decision

  • The trial court dismissed Mirasol's complaint, ruling that:
    1. Mirasol owned only 2/5 of the lot, and his claim to the 3/5 share was uncertain due to the unresolved probate of Asuncion's will.
    2. There was no proof that the gasoline station was built on Mirasol's 2/5 share.
    3. The lease agreement was valid until 1959, and the action for unlawful detainer was premature.

Issue:

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Ruling:

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Ratio:

  1. Ownership and Lease Rights:

    • Mirasol's ownership of the 2/5 share is undisputed. The defendants' lease rights are confined to this portion, regardless of its unsegregated status or the unresolved ownership of the 3/5 share.
    • The gasoline station could only have been lawfully constructed on Mirasol's 2/5 share, as per the lease agreement.
  2. Validity of the Lease Extension:

    • The lease extension executed by Jose Mesa on March 23, 1956, was null and void because Mesa no longer had authority to act on behalf of the Miraflores heirs after the property was sold to Mirasol on June 15, 1955.
  3. Obligation to Pay Rentals:

    • Upon being notified of the sale, the defendants were obligated to pay rentals to Mirasol, the new owner. Their refusal to do so entitled Mirasol to evict them and recover unpaid rent.
    • The increase in rent for Magsuci would apply from February 6, 1956, while Laygo and Natal would pay P10.00 monthly from the date of receipt of Mirasol's demand.
  4. Estoppel:

    • The defendants are estopped from denying that the leased portion corresponds to Mirasol's 2/5 share, as they had acknowledged this in their lease agreements.

Concurring Opinion

Justice J.B.L. Reyes concurred, emphasizing that the defendants are estopped from disputing the location of the leased portion, as they had acknowledged it as part of the lessor's 2/5 share.


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