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case digests - Sagrada Orden vs. National Coconut Corporation
Sagrada Orden vs. National
Coconut Corporation
91 SCRA 503
FACTS
Petitioner, Sagrada Orden owned a
land which was acquired by a Japanese corporation during the Japanese military
occupation. After the liberation, the Alien Property Custodian took possession,
control and custody of the land. The Copra Export Management Company occupied
the property and when it vacated, the
respondent, National Coconut
Corporation occupied it through the representation made by the Philippine Government
to the Alien Property Custodian. The property was returned to Sagrada Orden
upon judgment that the contract of sale of the property in favour of the
Japanese corporation was null and void and upon payment of the consideration it
received for the property to the Philippine Alien Property Administration.
Sagrada Orden was also given the right to recover from National Coconut
Corporation reasonable rentals for the use and occupation of the premises. Sagrada
Orden filed an action to recover rentals from National Coconut Corporation from
the time it used and occupied the premises. National Coconut Corporation claimed
that it was willing to pay only from the time the property was returned to
Sagrada Orden and not before, for it occupied the property in good faith, under
no obligation to pay the rentals.
ISSUE
Was National Coconut Corporation
liable for rentals prior to the date the property was returned to Sagrada
Orden?
RULING
No. National Coconut Corporation was
not liable for the rentals prior to the date the property was returned to
Sagrada Orden. For National Coconut Corporation to be liable, its obligation
must arise from the law, contract or quasi- contract, crime or negligence as
provided by Article 1157 of the Civil Code which was taken from Article 1089 of
the old Civil Code. As none of these sources were present, National Coconut
Corporation cannot be held liable. There was also no express agreement between
the entity which had legal control and administration of the property and the
National Coconut Corporation for the latter to pay rentals on the property so
there was no obligation.
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