Cruz v. Seminario de la Archidiocesis de Manila
REITERATIONFacts
1. The Antecedents: Cayetano de la Cruz, a member and president of a Methodist Episcopal association, was authorized to lease a building site and construct a chapel using contributed funds. He leased a lot from J. C. Miller, agent for the Archbishop of Manila, and proceeded to build a chapel. Subsequently, an action of forcible entry and detainer was filed against de la Cruz and Miller, resulting in a judgment that led to the destruction of the chapel. De la Cruz then initiated this action to recover damages for breach of the rental contract. 2. Procedural History: Following the destruction of the chapel, Cayetano de la Cruz commenced an action in the Court of First Instance of Manila seeking P2,000 in damages. The appellants demurred, arguing lack of jurisdiction due to the real estate's location and insufficient facts. The demurrer was overruled. An amended complaint was later admitted, adding unnamed parties plaintiff and reducing the damages sought to P402. The court rendered judgment for the appellees for P402. The appellants moved for a new trial, which was denied, and they subsequently appealed to the Supreme Court. 3. The Petition: The appellants, in their appeal to the Supreme Court, raised three main points: (1) the Court of First Instance of Manila lacked jurisdiction as the action concerned damages to real estate in Bataan; (2) the court erred in admitting the amended complaint to include other interested parties; and (3) the appellants are not liable for the consequences of the justice of the peace's judgment. The Supreme Court considered these arguments, affirming the lower court's decision.
Issue(s)
Whether the Court of First Instance of Manila had jurisdiction over the action for breach of a lease contract involving property in Bataan. Whether the amended complaint, which included other interested parties, was properly admitted. Whether the appellants are liable for the consequences of the judgment rendered in the forcible entry and detainer case.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, ordering the appellants to pay P402 to the appellees, with costs against the appellants.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the action for breach of covenant in a lease is personal and transitory, not local. It is founded on privity of contract, not privity of estate. Therefore, the Court of First Instance of Manila had jurisdiction, and Section 377 of the Code of Civil Procedure, which pertains to actions for injuries to real estate, was not applicable. The fact that damages to real estate were involved as an incident to the breach did not change the nature of the action. The Court cited Neil vs. Owen and other authorities to support the principle that actions founded on privity of contract are transitory. On the admission of the amended complaint: The Court found that the amendment was properly allowed under the broad terms of Section 110 of the Code of Civil Procedure. Furthermore, Section 118 of the same code was intended to avoid the difficulty and expense of requiring all interested persons to be made parties plaintiff. Since Cayetano de la Cruz was chosen by the association members to represent their interests, it was appropriate for him to represent them in the action, carrying out their desires and purposes. On the liability for the justice of the peace's judgment: The Court disagreed with the appellants' contention that they were not liable because de la Cruz entered the lot in violation of Sinsuangco's rights. The Court found that the agent, Miller, led de la Cruz to believe he could place him in legal possession. Although Miller did not have legal possession himself, and Sinsuangco was in actual possession, Miller should have known this and could not provide legal, peaceful, and quiet possession. The plaintiff took possession under these circumstances and constructed the chapel. Under Articles 1554 and 1568 of the Civil Code, the lessor has an obligation to maintain the lessee in the peaceful enjoyment of the premises. By failing to provide legal possession and maintain peaceful enjoyment, the defendants breached their contract, making them liable for damages under Article 1101 of the Civil Code.
Main Doctrine
An action for breach of covenant in a lease is personal and transitory, even if damages to real estate are involved as an incident, and is not governed by rules on actions for injuries to real property which are local.