Case Digest (G.R. No. L-10394)
Facts:
- The case "Vda. de Villaruel v. Manila Motor Co., Inc." (G.R. No. L-10394) was decided on December 13, 1958, by the Philippine Supreme Court.
- Plaintiffs-appellees, Claudina Vda. de Villaruel and others, leased several properties in Bacolod to the defendant-appellant, Manila Motor Co., Inc., on May 31, 1940.
- The lease included a building for an automobile showroom, a repair shop, and a residential house for the branch manager.
- The lease term was five years starting from October 31, 1940, with a monthly rental of P300 for the commercial properties and P50 for the residential house.
- During World War II, Japanese military forces occupied Bacolod and seized the leased premises from June 1, 1942, to March 29, 1945, ousting the lessee.
- No rent was paid during this period.
- After liberation, the U.S. Army occupied the premises until October 31, 1945, paying rent to the lessors.
- The lessee renewed the lease for another five years starting June 1, 1946, and sublet the premises to Arturo Colmenares.
- The lessors demanded rent for the period of Japanese occupation, which the lessee refused to pay, leading to a legal dispute.
- During the pendency of the case, a fire destroyed the leased buildings, and the lessors sought reimbursement for the loss.
- The Court of First Instance of Negros Occidental ruled in favor of the lessors, ordering the lessee to pay various sums, including the value of the destroyed buildings.
- The defendants appealed the decision.
Issue:
- (Unlock)
Ruling:
- The lessee is not liable for rent during the period of Japanese military occupation.
- The lessors' refusal to accept current rent payments without qualification placed them in default.
- The les...(Unlock)
Ratio:
- The Supreme Court held that the Japanese military occupation constituted a "trespass under color of title" (perturbacion de derecho) recognized by international law, which exempted the lessee from paying rent during the period of dispossession.
- The court cited international law principles that allow a belligerent occupant to use private property for military purposes without compensation.
- The lessors' insistence on collecting rent for the occupation period was unwarranted, an...continue reading
Case Digest (G.R. No. L-10394)
Facts:
The case "Vda. de Villaruel v. Manila Motor Co., Inc." (G.R. No. L-10394) was decided on December 13, 1958, by the Philippine Supreme Court. The plaintiffs-appellees, Claudina Vda. de Villaruel and others, leased several properties in Bacolod to the defendant-appellant, Manila Motor Co., Inc., on May 31, 1940. The lease included a building for an automobile showroom, a repair shop, and a residential house for the branch manager, with a term of five years starting from October 31, 1940, and a monthly rental of P300 for the commercial properties and P50 for the residential house. During World War II, Japanese military forces occupied Bacolod and seized the leased premises from June 1, 1942, to March 29, 1945, ousting the lessee. No rent was paid during this period. After liberation, the U.S. Army occupied the premises until October 31, 1945, paying rent to the lessors. The lessee renewed the lease for another five years starting June 1, 1946, and sublet the premises to Arturo Colmenares. The lessors demanded rent for the period of Japanese occupation, which the lessee refused to pay, leading to a legal dispute. During the pendency of the case, a fire destroyed the leased buildings, and the lessors sought reimbursement for the loss. The Court of First Instance of Negros Occidental...