Title
Chua Peng Hian vs. Court of Appeals
Case
G.R. No. 60015
Decision Date
Dec 19, 1984
A lessee refused to vacate leased property after expiration; court upheld lease terms, transferring ownership of improvements to lessor's heirs.

Case Summary (G.R. No. 60015)

Background of the Lease Agreement

Miguel C. Veneracion originally leased the lot to Patrick Chua in 1948 for a duration of ten years, which was subsequently renewed for another ten years. This lease facilitated the construction of a two-storey building by Chua, who operated his sawmill and lumber business on the ground floor and resided with his family on the second floor. Following the expiration of the second lease, on May 25, 1968, a new lease agreement was made for 1,850 square meters of the lot for three years, during which specific terms regarding the termination and possession of the premises were established.

Key Provisions of the Lease Contract

The new lease agreement contained pivotal stipulations regarding its automatic termination without extension, requiring the lessee to vacate the premises. Notably, Paragraph 7 mentioned that any buildings and improvements made by the lessee would automatically become the property of the lessor upon failure to vacate, with no need for a formal deed of transfer. Furthermore, Chua agreed to pay P20,000 in compensatory damages plus attorney's fees should he violate the lease terms.

Death of the Lessor and Actions Taken

Miguel Veneracion passed away on February 6, 1969, while the lease was still in effect. After the lease expired on May 1, 1971, Veneracion's heirs demanded that Chua vacate the premises and settle the accrued rentals. Chua's failure to comply prompted the heirs to file a specific performance action in the Court of First Instance of Nueva Ecija on April 11, 1972.

Court Proceedings and Decisions

The trial court found in favor of the heirs, leading to appeals from both parties. On October 30, 1980, the Court of Appeals ruled that Chua must vacate the property, convey the buildings to the Veneracion heirs, and pay outstanding rent and damages.

Issues of Jurisdiction

Chua contested the jurisdiction of the Court of First Instance over the case, arguing that it should have been within the purview of lower courts. However, it was established that the case did not solely concern possession but also the rights associated with the constructed building, thus necessitating the original jurisdiction of the Court of First Instance as affirmed by precedential rulings.

Property Rights and Lease Terms

The Court rejected Chua's argument that his actions constituted an illegal disposition of conjugal property without his wife’s consent, ruling that the buildi

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