Case Digest (G.R. No. 125497)
Facts:
- Unicane Food Products Manufacturing, Inc. (petitioner) filed a case against the Hon. Court of Appeals and the spouses Pablo and Felisa Manese, spouses Nicanor and Lutgarda Velasquez, and Ciceron Manese (respondents).
- On June 6, 1975, Felisa Feliciano Manese entered into a lease contract with Roberto Regala Keh Yung for a parcel of land in San Fernando, Pampanga, for fifteen years at an annual rental of P10,000.
- An amendment designated Unicane as the actual lessee while retaining the original lease terms.
- Unicane paid advance rentals and, in 1987, verbally agreed with Felisa to extend the lease until December 7, 1997, with an additional advance rental of P20,000.
- On September 6, 1978, Felisa sold the property to her daughters Lutgarda and Ciceron Manese for P15,000 without her husband’s consent, with the understanding that the property would revert to her later.
- A new title was issued in the daughters' names, leading Unicane to demand the sale be disregarded, asserting its preferential option to buy.
- The daughters refused to extend the lease beyond 1990, prompting Unicane to file a complaint for annulment of the deed of sale in the Regional Trial Court.
- On September 8, 1992, the trial court ruled in favor of Unicane, but the Court of Appeals reversed this decision on February 29, 1996, leading to Unicane's petition for review on certiorari.
Issue:
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Ruling:
- The Court ruled that advance rentals covered by receipts cannot be considered as evidence of an extension of the lease agreement.
- The Court affirmed that the deed of absolute sale was simulated and not enforceable.
- The Court concluded that Uni...(Unlock)
Ratio:
- The Supreme Court emphasized that advance rental payments made by Unicane could not be interpreted as an extension of the lease, particularly because Felisa Manese, being elderly and illiterate, was not adequately informed about the implications of the receipts she signed.
- The Court referenced Article 1332 of the Civil Code, which places the burden on the party enforcing a contract to prove that the terms were fully explained to a party who cannot read or understand the contract.
- The Court found that Unicane failed to meet this burden, indicating that the intention to extend the lease was not properly communicate...continue reading
Case Digest (G.R. No. 125497)
Facts:
The case involves Unicane Food Products Manufacturing, Inc. (petitioner) against the Hon. Court of Appeals and the spouses Pablo and Felisa Manese, spouses Nicanor and Lutgarda Velasquez, and Ciceron Manese (respondents). The events leading to the case began on June 6, 1975, when Felisa Feliciano Manese entered into a contract of lease with Roberto Regala Keh Yung for a parcel of land in San Fernando, Pampanga, for a period of fifteen years at an annual rental of P10,000. Shortly after, an amendment was made to the lease, designating Unicane as the actual lessee while retaining the original terms. Unicane complied with the lease terms, paying advance rentals. In 1987, Felisa and Unicane verbally agreed to extend the lease until December 7, 1997, with Unicane paying an additional advance rental of P20,000.
However, on September 6, 1978, Felisa sold the property to her daughters Lutgarda and Ciceron Manese for P15,000 without her husband’s consent, with the understanding that the property would revert to her once her daughters' financial situation improved. This sale led to a new title being issued in the daughters' names. Unicane later discovered this sale and demanded that it be disregarded, asserting its preferential option to buy the property as stipulated in the lease. The daughters refused to extend the lease beyond 1990, prompting Unicane to file a complaint for annulment of the deed of sale in the Regional Trial Court of San Fernando, Pampanga.
On September 8, 1992, the trial court ruled in favor of Unicane, declaring the lease extended until 1997 and nullifying the sale to the daughters. The respondent...