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C To c7 Case Digests

The document summarizes 5 cases from the Supreme Court of the Philippines: 1. Caleon v. Agus Development Corporation ruled that leasing an apartment building also implied leasing the underlying land and that laws restricting subleasing apply to contracts. 2. Consuelo Piczon v Esteban Piczon stated that interest on a loan should accrue from the date of the contract, not the date of demand, and that the defendant was only a guarantor, not a surety. 3. Chavez v Gonzales determined that a person contracted to fix an item must pay the full cost of repairs if they damage the item further instead of fixing it. 4. San Lorenzo Development

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0% found this document useful (0 votes)
77 views

C To c7 Case Digests

The document summarizes 5 cases from the Supreme Court of the Philippines: 1. Caleon v. Agus Development Corporation ruled that leasing an apartment building also implied leasing the underlying land and that laws restricting subleasing apply to contracts. 2. Consuelo Piczon v Esteban Piczon stated that interest on a loan should accrue from the date of the contract, not the date of demand, and that the defendant was only a guarantor, not a surety. 3. Chavez v Gonzales determined that a person contracted to fix an item must pay the full cost of repairs if they damage the item further instead of fixing it. 4. San Lorenzo Development

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Caleon v. Agus Development Corporation, GR No.

77365, April 7, 1992


FACTS: Agus Development Corporation leased a parcel of land to Rita Caleon. The latter built
a 4-door apartment building on the lot and, without the written consent of the respondent,
subleased 2 of the rooms. Agus Development Corporation demanded Caleon and her
tenants to vacate the lot, invoking Batas Pambansa (BP) 25, Section 5. Caleon argued that
she was leasing only the rooms and not the lots. Furthermore, her contract lacked any
express prohibition on subleasing.
ISSUES:
1. Whether or not the lots were included in the leasing of the rooms.
2. Whether or not BP 25 is applicable to contracts.
SC:
1. YES. Art. 1166 of the Civil Code states that The obligation to give a determinate thing
includes that of delivering all its accessions and accessories, even though they may not
have been mentioned. Because the apartment building takes up space on the parcel of
land, the lot itself is a logical accessory to the leasing of the room.
2. YES. Art. 1163 of the Civil Code states that Every person obliged to give something is
also obliged to take care of it, unless the law requires another standard of care. BP 25 is
an example of such a law. It is derived from P.D. No. 20, which has been declared by the
Supreme Court as police power legislation. It must be applied to protect the interests of
public health, safety, morals and general welfare

Consuelo Piczon v Esteban Piczon, GR L-29139, November 15, 1974


FACTS: On September 28, 1956, Sosing-Lobos and Co. obtained a loan of P 12,500 from
Piczon Co. with 12% interest per annum. Defendant Esteban Piczon signed himself as the
guarantor. When the deadline passed, plaintiff Consuelo Piczon brought action to recover the
amount loaned. The Court of First Instance of Samar sentenced the defendants to pay the
sum of P12,500.00 with 12% interest accruing from August 6, 1964: the date plaintiff made
the first demand. Plaintiff appealed the case, arguing that interest should begin on the day
the contract was made and that Esteban Piczon was also a surety.
ISSUE:
1. Whether or not the 12% interest should begin on August 6, 1964.
2. Whether or not Esteban Piczon was a guarantor only.
SC:
1. NO. The trial court should have adhered to the terms of the agreement which plainly
provides that Esteban Piczon had obligated Sosing-Lobos and Co., Inc. and himself to
"return or pay (to Piczon and Co., Inc.) the same amount (P12,500.00) with Twelve Per
Cent (12%) interest per annum commencing from the date of the execution hereof"; that
is, starting on September 28, 1956.
2. YES. The contract does not say anything about Esteban Piczon being a surety. As it
explicitly states that he is a guarantor, he is only obligated to act as such.

Chavez v Gonzales, GR L-27454, April 30, 1970

FACTS: Rosendo Chavez hired Fructuoso Gonzales to fix his typewriter. The latter asked for P
6.00 to purchase missing parts and the former complied. Despite repeated reminders to fix
the typewriter, Gonzales failed to do so. He returned the typewriter in shambles, along with
the P 6.00. Chavez eventually got the typewriter repaired for P 89.85 at Freixas Business
Machines and subsequently filed a case against Gonzales. The City Court directed Gonzales
to pay the cost of the missing parts amounting to P 31.10. Chavez appealed the case on the
grounds that Gonzales ought to pay the entire amount of the repair.
ISSUE: Whether or not Gonzales must pay the entire price of the typewriter repair.
SC: YES. Art. 1167 states that If a person obliged to do something fails to do it, the same
shall be executed at his cost. This same rule shall be observed if he does it in contravention
of the tenor of the obligation. Furthermore, it may be decreed that what has been poorly
done be undone. Gonzales was contracted to fix the typewriter; however, he returned it in a
worse state. Thus, he must pay the balance of the repair amounting to P 58.75.

San Lorenzo Development Corporation v. CA, GR 124242, January 21, 2005


FACTS: In 1986, Miguel and Pacita Lu planned to sell two lots to Pablo Babasanta for P15 per
square meter. The latter gave them P 50,000 as down payment, and made subsequent
payments amounting to P200,000. Babasanta tried to convince the couple to lower the price
of the land, but they refused. On May 1989, Babasanta demanded the deed of sale, stating
that he would pay the full price after receiving it. However, the Lu couple did not push
through with the sale. At the subsequent trial, San Lorenzo Development Corporation
testified saying that it bought the two lots from the Lus at full price. Babasanta argued that
his right to the two parcels of land was superior due to the arrangements having been made
first.
ISSUE: Whether or not Babasantas claim over the land was valid.
SC: NO. There was no double sale in this case because the contract in favor of Babasanta
was a mere contract to sell, not a contract of sale. Babasantas attempts to lower the price
and to ask for the deed of sale are evidences that he recognized that ownership of the lots
would not be transferred to him until final payment. Art. 1164 of the Civil Code states that
The creditor has a right to the fruits of the thing from the time the obligation to deliver it
arises. However, he shall acquire no real right over it until the same has been delivered to
him. As the deed of sale had yet to be delivered to Babasanta, he has no real right over the
properties.

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