Case Summary (G.R. No. 137171)
Nature of the Lease Agreement
On May 17, 1984, a lease agreement was formalized between Kho and Biron concerning a 30-hectare portion of Lot No. 738-B-9. The contract outlined an annual rental fee of P120,000, with specific payment schedules. The lease was set to commence on January 1, 1985, and continue over a period of seven years. Kho later alleged discrepancies regarding the land area delivered under this agreement.
Initiation of Legal Action
On June 26, 1989, Kho filed a complaint in the Regional Trial Court (RTC) of Bacolod City, seeking specific performance, refund of overpayment, and damages. She claimed that Biron delivered only 23.26 hectares, which constituted a shortfall of 6.74 hectares from the agreed area. In response, Biron maintained that Kho had no valid claims due to alleged laches and subsequent agreements made after the contract had been executed.
Respondent's Defense
Biron contested Kho’s assertions by stating that he had delivered the appropriate land area and that Kho had taken possession of additional areas outside the original lease. He argued that after the execution of the lease, they mutually altered specific terms, including the effective date of the lease and the land area covered, due to other arrangements made by Kho. Her early payment inconsistencies and attempts to shift to an adjoining lot also supported his defense.
Trial Court's Decision
The RTC ruled in favor of Biron on September 30, 1993, dismissing Kho's complaint and rescinding the lease contract. The court noted Kho's failure to demonstrate the existence of the remaining 6.74 hectares and held her liable for unpaid rentals, along with damages and attorney's fees.
Appeal and Court of Appeals Ruling
Kho appealed to the Court of Appeals (CA) under CA-G.R. CV No. 44614. The CA affirmed the RTC's decision on October 16, 1998, maintaining the view that the findings of fact from the RTC were authoritative and unchallengeable. The CA also addressed Kho's allegations of errors by reiterating that she failed to substantiate her claims against Biron's assertions.
Supreme Court's Findings
The Supreme Court reiterated the principle that findings of fact by lower courts are binding unless demonstrably erroneous. The Court found no evident arbitrariness in the CA’s affirmation of the trial court's ruling. It highlighted Kho's lack of evid
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Case Citation
- Jurisprudence: 527 Phil. 339
- Second Division, G.R. No. 137171, July 14, 2006
Parties Involved
- Petitioner: Maria Z. Kho
- Respondent: Federico Biron, Sr.
Background of the Case
- The case arises from a petition for review on certiorari filed by Maria Z. Kho, seeking to reverse the Court of Appeals (CA) decision dated October 16, 1998, which affirmed a decision by the Regional Trial Court (RTC) of Bacolod City.
- The petitioner filed a complaint for specific performance, refund of overpayment of rentals, and damages against the respondent.
Facts of the Case
- On May 17, 1984, a lease contract was executed between the petitioner and respondent concerning a 30-hectare portion of land (Lot No. 738-B-9) located in E.B. Magalona, Negros Occidental.
- The lease was to last for seven years, commencing January 1, 1985, with an annual rental of P120,000.00.
- Petitioner alleged that upon conducting a geodetic survey in May 1987, she discovered that the respondent had only delivered approximately 23.26 hectares instead of the contracted 30 hectares, leading to her claims for the remaining area and a refund of P106,240.00.
Respondent's Defense
- The respondent contended that the petitioner had no cause of action and was guilty of laches.
- He asserted that the area actually leased was less than