Case Summary (G.R. No. 161722)
Background of the Dispute
The case revolves around a dispute concerning a 9,646 square meter parcel of land in Niog, Bacoor, Cavite, which is owned by Angel Miranda. In 1984, a verbal lease was established between Angel and EMECO, owned primarily by Angelito Miranda, Angel's son, enabling EMECO to use the property for factory purposes. Upon Angelito's death in 1988, EMECO ceased paying rent but retained possession of the property. In 1989, the factory was destroyed by fire, and in subsequent years, Angel Miranda made demands for unpaid rents, ultimately terminating the lease and seeking possession of the property.
Lease Agreement and Forcible Eviction
In December 1991, G.Q. Garments, Inc., represented by its Executive Vice-President Davy John Barlin, entered into a formal lease agreement with Angel Miranda for a 15-year term starting February 1, 1992. The petitioner paid upfront fees totaling P360,000.00. However, on January 27, 1992, Florenda Miranda, along with armed individuals claiming to be from the police, forcibly evicted G.Q. Garments from the property. Consequently, G.Q. Garments sought legal remedies including damages and recovery of possession of the property.
Pending Litigation and Court Proceedings
Angel Miranda filed an action to declare the purported contract of lease between himself and EMECO void, claiming forgery. Meanwhile, G.Q. Garments filed a separate suit for recovery of possession and damages against Florenda and EMECO in the RTC of Cavite. A judge ruled in favor of G.Q. Garments, stating that eviction of Florenda and all those claiming rights under her was justified, but the judgment was dismissed in respect of the other defendants due to litigation pendency.
Decisions in Lower Courts
On November 26, 1993, the RTC ruled against G.Q. Garments on its claim for damages but recognized its right to claim damages later on. Angel Miranda's separate case to void the lease was decided in his favor on September 22, 1994. The Court of Appeals later dismissed G.Q. Garments' claims for damages against Angel Miranda, asserting that Angel was not liable for the acts committed by Florenda Miranda and that such actions represented mere physical trespass.
Liability for Damages
The Court of Appeals ruled that while G.Q. Garments suffered losses, adequate evidence did not substantiate the claims of damages reaching P10,000,000.00. The appellate court emphasized that actual damages required clear proof and could not merely be based on the claimant's assertions. The ruling further delineated that under Article 1654 of the New Civil Code, lessors are only liable for failing to maintain legal possession and are not responsible for acts of trespass performed by third parties unless they actively participated in such acts.
Final Judgment
In its ruling dated October 29, 2002, the Court of Appeals reversed the decision of the RTC, affirming that while Florenda Miranda was liable for the damages incurred by G.Q. Garments, Angel Miranda could not be held accountable as he did not partake in the acts leading to G.Q. Garments' losses. The appellate court awarded nominal damages to G.Q. Garments for its claims while absolving Angel Miranda of any financial liability regarding the forcible eviction and property damage.
Petitioner’s Cl
...continue readingCase Syllabus (G.R. No. 161722)
Case Background
- The case is a Petition for Review on Certiorari aimed at reversing the Decision of the Court of Appeals (CA) in CA-G.R. CV No. 45567.
- The central dispute involves a parcel of land owned by Angel Miranda, which was leased to the Executive Machineries and Equipment Corporation (EMECO), founded by his son, Angelito Miranda.
- The verbal lease agreement allowed EMECO to build a factory on the property at a monthly rental fee of P8,000.
Lease Agreement and Subsequent Events
- EMECO initially paid the agreed rentals until Angelito's death in 1988, after which the company failed to pay but continued to occupy the premises.
- A fire destroyed EMECO's factory on November 19, 1989, and Angel Miranda demanded the payment of accrued rentals amounting to P280,000 in 1991, which went unpaid.
- Florenda Miranda, Angelito's widow, attempted to sublease the property to Wilson Kho without Angel's consent, which led to further complications.
Legal Actions Initiated
- On December 23, 1991, Angel Miranda entered into a new lease agreement with G.Q. Garments, Inc., represented by Davy John Barlin, for a 15-year term at a monthly rental of P30,000.
- Florenda, alongside armed men, forcibly evicted G.Q. Garments from the property on January 27, 1992, claiming ownership and asserting the existence of a prior lease agreement.
Court Proceedings
- Angel Miranda f