Case Digest (G.R. No. L-23302)
Facts:
Alejandro Ras v. Estela Sua and Ramon Sua, G.R. No. L-23302, September 25, 1968, the Supreme Court En Banc, Reyes, J.B.L., J., writing for the Court.Plaintiff Alejandro Ras purchased a parcel of land from the National Abaca and Other Fibers Corporation (NAFCO) on installment on 31 August 1951 (Exhibit A). On 25 February 1958 he executed a lease of a four-hectare parcel (Lot No. 52, Balactasan, Lamitan District, Basilan City) to spouses Ramon and Estela Sua for three years (1 April 1958–1 April 1961) for P2,500, the lease obligating the lessees to pay government installments and taxes on the land.
Thereafter the parties executed successive extension agreements: Exhibit D (dated 1 October 1958) extending the lease to 2 April 1963 for P1,000; Exhibit E (1 December 1959) to 2 April 1964 for P400; Exhibit F (29 July 1960) to 2 April 1966 for P600; and Exhibit G (26 January 1962) to 2 April 1968 for P600. Ras alleged defendants failed to pay taxes and NAFCO installments and harvested coconuts from the land; the original complaint (dated 6 May 1963, amended 14 August 1963) sought rescission or annulment of the contracts, recovery of possession, value of harvested coconuts, damages and attorney’s fees.
The spouses answered denying breach, challenged the court’s jurisdiction to order return of the land and filed a counterclaim. They moved to dismiss during trial on grounds of prescription (arguing the action was one for rescission under Art. 1191, Civil Code, with a four-year prescriptive period) and contended plaintiff failed to prove material breach.
On 3 April 1964 the Court of First Instance of Basilan City rendered judgment for plaintiff, finding violation of the lease (failure to pay taxes) and that the lease was prohibited under Section 8 of Republic Act No. 477; the trial court annulled Exhibits F and G, ordered defendants to pay P110 monthly from 2 April 1964 until possession was restored, a...(Pro-only)
Issues:
- Is appellee’s action barred by prescription?
- Does appellee have the personality to seek annulment/recovery of the land and do the courts have jurisdiction rather than the Board of Liquidators or the State?
- Are the lease contracts void under Section 8 of Republic Act No. 477, and if so, does that produce automatic reversion to the State or bar appellee’s recovery u...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)