Case Summary (G.R. No. 2285)
Procedural Background
The original judgment, entered on May 21, 1903, confirmed the title of the Obras Pias to specific houses located on Calle Magallanes, Manila, which were previously in the possession of Ricardo Regidor. Following this judgment, a writ of execution was issued to the sheriff, who subsequently placed the Obras Pias in possession of the property. At the time of the judgment, the defendants, Williams, Chandler & Co., were tenants of the property under Regidor's lease agreement.
Lease Agreement and Rent Payments
Under the lease agreement attributed to Regidor, rent was payable in advance within the first five days of each month. Accordingly, the rent for May 1903 was due before May 5. On May 13, Regidor assigned his right to collect the rent for that month, amounting to $325, to Waite, the plaintiff. The defendants were notified of this assignment on May 16 and were subsequently required to make payment for the assigned rent, which they refused to pay.
Disputed Rent Allocation
After the court’s decision on May 21, the defendants were informed to direct rent payments to the Obras Pias rather than to Regidor. The defendants paid the portion of the rent corresponding to their lease for the period from May 21 to the end of the month but retained a balance of $216.66, which was not paid to either Waite or the Obras Pias.
Legal Argument and Findings
The defendants contended that the Obras Pias were a necessary party to the suit. However, this argument was not previously raised at the trial level and was thus regarded as waived. The court identified that the rents in question were classified as civil fruits under the Civil Code. Regidor had rightful ownership of the property for the first twenty days of May, while the Obras Pias owned it for the remaining ten days, entitling each party to a proportionate share of the monthly rent based on the time of ownership.
Court Decision
Consequently, the court concluded that Regidor was entitled to the rent accrued for the first twenty days of May, while the Obras Pias were entitled to the rent for the last ten days. Since Regidor had assigned his rights to receive rent for the entire month to Waite, he was entitled to coll
...continue readingCase Syllabus (G.R. No. 2285)
Case Overview
- Citation: 5 Phil. 571 [G.R. No. 2285. January 25, 1906]
- Court: Supreme Court of the Philippines
- Plaintiff: Frederick Garfield Waite
- Defendants: Williams, Chandler & Co.
- Decision Date: January 25, 1906
- Judge: Willard, J.
Background of the Case
- The case stems from a prior decision rendered on May 21, 1903, in the case of La Junta Administradora de Obras Pias vs. Regidor, wherein the Obras Pias were declared the owners of certain properties on Calle Magallanes, Manila.
- The properties had been in the possession of Ricardo Regidor for over twenty years prior to this judgment.
- On May 21, 1903, after the execution of the judgment, the Obras Pias were put in actual possession of the properties.
Relevant Contracts and Assignments
- Regidor had leased the properties to the defendants, Williams, Chandler & Co., under a written contract stipulating that rent was due in advance within the first five days of each month.
- The rent for May 1903 was due before May 5, 1903.
- On May 13, 1903, Regidor assigned his right to collect the rent for May, amounting to $325, to the plaintiff, Frederick Garfield Waite.
- The defendants were notified of this assignment on May 16, 1903, and a demand for payment was made, which the defendants refused.