Showing posts with label Sagrada Orden vs. National Coconut Corporation. Show all posts

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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case digests - Sagrada Orden vs. National Coconut Corporation

Sagrada Orden vs. National Coconut Corporation

91 PHIL. 503

FACTS
Plaintiff Sagrada Orden owned a piece of real property in Pandacan, Manila. During the Japanese occupation, the land was acquired by a Japanese corporation Taiwan Tekkoshho. After the liberation, the Alien Property Custodian of the United States took possession, control, and custody of the real property. During the year 1946, the property was occupied by the Copra Export Management Company under the custodianship agreement with United States Alien Property Custodian, and when it vacated, the property 
occupied by defendant National Coconut Corporation. Sagrada Orden made claim to the property before the Alien Property Custodian of the United States but was denied. So plaintiff brought an action in court to annul the sale of property of Taiwan Tekkosho, and recover its possession. The case did not come for trial because the parties presented a joint petition in which it is claimed by Sagrada Orden that the sale in favor of Taiwan Tekkosho was null and void because it was executed under threats, duress, and intimidation, and that the title be re-issued to Sagrada Orden. The court rendered judgment releasing the defendant from liability, but reversing to the plaintiff the right to recover from the defendant reasonable rentals for the use and occupation of the premises. The present action to recover the reasonable rentals from August 1946, the date when defendant began to occupy, to the date it vacated it. The defendant did not contest its liability for the rentals at the rate of P3, 000 per month from February 28, 1949, but resisted the claim therefore prior to that date. Defendant contends that it occupied the property in good faith, under no obligation to pay rentals for the use and occupation. Judgment rendered for the plaintiff to recover from the defendant the sum of P3, 000 a month, from August, 1946, to the date the defendant vacates the premises. Thus this appeal made by defendant.


ISSUE
Can the defendant company be held liable to pay rentals from August 1946 to the date it vacated?

RULING
No. If defendant-appellant is liable at all, its obligations, must arise from any of the four sources of obligations, namely, law, contract or quasi-contract, crime, or negligence. Defendant-appellant is not guilty of any offense at all, because it entered the premises and occupied it with the permission of the entity which had the legal control and administration thereof, the Alien Property Administration. Neither was there any negligence on its part. There was also no privity between the Alien Property Custodian and the Taiwan Tekkosho, which had secured the possession of the property from the plaintiff-appellee by the use of duress, such that the Alien Property Custodian or its permittee (defendant-appellant) may be held responsible for the supposed illegality of the occupation of the property by the said Taiwan Tekkosho. The Alien Property Administration had the control and administration of the property not as successor to the interests of the enemy holder of the title, the Taiwan Tekkosho. Neither is it a trustee of the former owner, the plaintiff-appellee herein, but a trustee of then Government of the United States, in its own right, to the exclusion of, and against the claim or title of, the enemy owner. From August, 1946, when defendant-appellant took possession, to the late of judgment on February 28, 1948, Alien Property Administration had the absolute control of the property as trustee of the Government of the United States, with power to dispose of it by sale or otherwise, as though it were the absolute owner. Therefore, even if defendant-appellant were liable to the Alien Property Administration for rentals, these would not accrue to the benefit of the plaintiff-appellee, the owner, but to the United States Government.
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