Santos v. Reyes
REITERATIONFacts
The Antecedents: Bonifacia de los Santos (plaintiff-appellant) leased a rural estate in May 1915 from the parish priest of Santa Rita, Pampanga, under a verbal contract for an annual rental of P70. The plaintiff paid rents for 1916, 1917, and 1918. In March 1919, the new parish priest, Father Tomas Dimacali, issued a receipt for P70, representing rent from May 1919 to May 1920. Father Dimacali was instructed to hand over management of the estate to Father Laureano de los Reyes. In July 1919, Father Laureano de los Reyes, through his agents (defendants-appellees), took possession of the land. The plaintiff alleged she was turned out of possession by the defendants in July 1919, while the lease contract was still in force due to implied renewal from her payment of rent. Procedural History: The action was originally commenced in the justice of the peace court to recover possession of the land. The justice of the peace ruled in favor of the plaintiff. The defendants appealed to the Court of First Instance, which dismissed the complaint. The plaintiff then appealed to the Supreme Court. The Petition: The plaintiff sought to recover possession of the leased property, asserting her right to peaceful possession based on an existing lease contract.
Issue(s)
Whether the plaintiff was unlawfully dispossessed of the leased property. Whether the lease contract was validly in force at the time of dispossession. Whether the plaintiff is entitled to the peaceful possession of the leased property.
Ruling
The Supreme Court ruled that the plaintiff is entitled to the peaceful possession of the leased property during the term of the contract. The judgment of the Court of First Instance was affirmed as to the agents (defendants Aurelio Lagman, Ambrosio Lagman, Simeon Duque, and Marcelo Santa Cruz) and reversed as to Father Laureano de los Reyes, who was ordered to deliver possession of the land to the plaintiff in accordance with the contract.
Ratio Decidendi
On whether the plaintiff was unlawfully dispossessed: The Court found that the plaintiff was turned out of possession by the defendants in July 1919. It rejected the lower court's finding that the plaintiff delivered the land without objection, deeming it unbelievable given that she had paid the rent for the period 1919-1920. The plaintiff's testimony, uncontradicted by Father Laureano de los Reyes and corroborated by a witness, established that she refused to deliver the land, although she did not use force. The act of entering and trespassing upon the land without the knowledge of the person administering it constitutes usurpation and dispossession. On whether the lease contract was validly in force: The Court held that the lease contract was in force. The verbal contract, initiated in May 1915, was for an unspecified duration and was renewed annually through the payment of rent. The plaintiff's payment of P70 in March 1919 for the period May 1919 to May 1920 constituted an implied renewal of the contract. Father Dimacali's receipt (Exhibit A) was considered authentic and binding, and he could not legally contradict its contents. Therefore, the contract was validly renewed and subsisting at the time the plaintiff was dispossessed. On whether the plaintiff is entitled to peaceful possession: The Court affirmed the plaintiff's right to peaceful possession. Citing Schultz vs. Concepcion and Roman Catholic Church vs. Familiar, the Court reiterated that a landlord cannot summarily enter and dispossess a tenant, even for nonpayment of rent, until the lease is legally terminated. The tenant has a right to possession until the lease is legally terminated. The plaintiff, being in possession by virtue of an implied renewal of the contract, was entitled to be respected in her possession. The dispossession by the defendants, acting as agents of Father Laureano de los Reyes, was unlawful.
Main Doctrine
A lessee in lawful possession of a leased property under an impliedly renewed contract is entitled to peaceful possession thereof for the term of the contract, and cannot be summarily dispossessed by the lessor without due process of law. The lessor cannot terminate the contract unilaterally and oust the lessee therefrom.