Ubaldo v. Lao-Jianquiao
REITERATIONFacts
The Antecedents: Plaintiff-lessor Maria Ubaldo filed an action for eviction against defendant-lessee Lao-Jianquiao. Ubaldo alleged that Lao-Jianquiao failed to pay for the cleaning of water-closets and stored several cases of coal oil in the leased premises, constituting breaches of the lease contracts. Procedural History: The lower court dismissed the complaint, finding that the alleged acts did not constitute a breach of the contract. The court reasoned that it was unlikely for a lessee who advanced a significant sum for rent to intentionally breach the contract and risk dispossession. The Petition: The plaintiff appealed the lower court's decision.
Issue(s)
Whether the failure to pay for cleaning the water-closets constitutes a breach of the lease contract. Whether the storing of cases of coal oil constitutes a breach of the lease contract.
Ruling
The judgment of the lower court is affirmed, with costs to the appellant.
Ratio Decidendi
On the failure to pay for cleaning the water-closets: The Court held that the term "cleaning" as used in clause 4 of the contracts did not, in either general or technical vocabulary, imply the specific obligation contended by the lessor. Nothing in the contract clearly and precisely established this as a burdensome obligation falling upon the lessee, which generally falls upon the lessor. Therefore, the failure to pay for this service did not constitute a breach. On the storing of cases of coal oil: The Court examined clause 5 of the contracts, which prohibited the storage of combustible articles that might imperil the building and neighborhood. The clause stipulated that if competent authorities demanded the removal of such items, the lessee would comply immediately and suffer the consequences. The Court found that the sanction for this condition was not judicial eviction but an administrative eviction if demanded by the competent authorities, not by the lessor. The contract clearly established that the lessee would be responsible to the proper administrative authorities for any breach of municipal ordinances regarding the storage of inflammable substances. Since the lessor did not demonstrate that the competent authorities had demanded the removal of the coal oil, the act of storing it did not constitute a breach warranting eviction by the lessor.
Main Doctrine
The penalty stipulated in a contract for infraction of its terms and conditions is the exclusive effect of the breach, and if the contract prescribes eviction by administrative authorities as the penalty, judicial eviction cannot be demanded by the lessor.