Title
Vda. de Miranda vs. Lim Shi
Case
G.R. No. L-18494
Decision Date
Dec 24, 1964
A 10-year lease expired; lessee sought renewal for another 10 years, but court ruled renewal was month-to-month due to contract silence on term. No damages awarded.

Case Digest (G.R. No. L-18494)

Facts:

Nieves Vda. de Miranda, etc., et al. v. Lim Shi, G.R. No. L-18494, December 24, 1964, Supreme Court En Banc, Bautista Angelo, J., writing for the Court.

The plaintiffs-appellants, Nieves Vda. de Miranda and her children, owned pro indiviso a residential lot in Zamboanga City which they leased to the defendant-appellant Lim Shi for ten years beginning January 18, 1940. The lease fixed a monthly rent of P200, required the lessee to construct a two-story commercial building whose improvements would become the lessors’ property at termination, and contained Clause VII giving the lessee a "preference to continue renting" the building but leaving the amount of rent on renewal to be "determined anew by the parties" taking into account current rentals; the clause was silent as to the duration of any renewal.

Shortly before the original term ended, the lessors in January 1959 asked whether the lessee wished to exercise the preferential option. On January 29, 1959, Lim replied he wished to renew for another ten years at an increased rent of P750 per month. The lessors agreed to the proposed rent but refused a ten‑year renewal, offering instead a one‑year concession and, if unacceptable, notice to vacate by end of February 1959. On February 17 Lim reiterated that the renewal should be for ten years (arguing silence as to term implies repetition of the original term) and tendered P750 for February; the tender was refused and Lim consigned the amount in court on February 27.

On March 18, 1959 the lessors filed suit for specific performance with damages in the Court of First Instance of Zamboanga City, alleging that, by holding over, the lessee had tacitly renewed the lease and should be ordered to execute a lease for the period the lessors proposed (one year). Lim answered contending that Clause VII entitled him to renew for ten years, that he had offered the P750 monthly rent which the lessors had accepted as reasonable, and praying that the court compel renewal for ten ...(Pro-only)

Issues:

  • Was the tacit renewal of the lease for a term equal to the original ten years, or was it for a shorter period (e.g., month‑to‑month)?
  • Are the lessors entitled to damages and attorn...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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