Title
Ng Siu Tam vs. Amparo
Case
G.R. No. L-2139
Decision Date
May 12, 1948
Sublessees bound by eviction judgment against lessors; alleged agreement with owner unproven, contradicted by sworn statements.
A

Case Digest (G.R. No. L-2139)

Facts:

  • Execution of the eviction order
    • On March 7, 1948, the sheriff of Manila took steps to execute the decision of the Court of First Instance in Civil Case No. 3527.
    • The order required Felipe Aguasin and his wife, the primary tenants, to vacate the premises in Echague Street owned by Jose M. Ocampo.
    • A command was given to cause all "tenants thereon" to leave the premises.
  • Petitioners’ status and response
    • The petitioners, Ng Siu Tam et al., were sublessees of Felipe Aguasin, operating stores within the premises.
    • They appeared before the court, contending that they were not parties to the original eviction case and therefore should not be bound by its decision.
    • The petitioners moved for a declaration stating that the decision did not affect them.
  • Court’s response to the petitioners’ motion
    • On March 13, 1948, the court denied the petitioners’ motion.
    • The court’s order provided a thirty-day period for the petitioners to remove their goods or merchandise or to take any further measures to protect their rights.
    • The petitioners’ motion for reconsideration was subsequently denied.
  • Background of the eviction and sublease arrangement
    • The premises in question are owned by Jose M. Ocampo.
    • Jose M. Ocampo had a final, enforceable eviction judgment against his tenants, the Aguasins.
    • The Aguasins had subleased the property to the petitioners, making them secondary occupants subject to the judgment.
  • Allegation of an alternative agreement
    • One petitioner's attorney attempted to secure a temporary injunction by alleging that the petitioners had an agreement with Ocampo.
    • The alleged agreement purportedly allowed petitioners to retain the premises under the same conditions given to the Aguasins.
    • Evidence against the validity of the alleged agreement included:
      • The absence of any written contract.
      • Sworn statements by three petitioners, admitting that no such contract was ever made by owner Ocampo.
    • Consequently, there was no substantiated legal basis to support the petitioners’ claim of an alternative arrangement.

Issues:

  • Applicability of the eviction judgment to sublessees
    • Does the eviction order against the primary tenants (Aguasins) extend to affect sublessees such as the petitioners?
    • Is the legal effect of the judgment binding on all occupants, regardless of whether they were parties to the original court action?
  • Validity of the alleged agreement with the property owner
    • Can the petitioners rely on their claimed agreement with Jose M. Ocampo to assert a right to remain in the premises?
    • Does the lack of a written contract, coupled with testimonial evidence to the contrary, undermine their claim?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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