Sagrada Orden de Predicadores del Santisimo Rosario

Filipinas vs. National Coconut Corporation [91 SCRA 503

G.R. No.L-3756 June 30, 1952]
Post under case digests, Civil Law at Tuesday, March 20, 2012 Posted by Schizophrenic Mind

Facts: Plaintiffs land was acquired during the Japanese

occupation by Taiwan Tekkosho for the sum of P140,000, and the
titled was issued in the Japanese corporations name. After
liberation, the Alien Property Custodian of USA took possession,
control, and custody of the land by virtue of the Trading with the
Enemy Act as it belonged to an enemy national. Then it was
occupied by NACOCO. Plaintiff then claimed the property through
an action in court. The parties then presented a joint petition
where plaintiff claims that the sale in favor of Taiwan Tekkosho
was void as it was executed under threats, duress, and
intimidation. It was agreed that the title would be cancelled and
re-issued in the name of plaintiff. It was also agreed that the
interest of the Alien Property Custodian of USA over the property
be cancelled and that NACOCO leave the premises.
NACOCO does not contest that he is liable for rent after the
judgment was rendered with regard to plaintiffs claim over the
property.
Issue: Whether NACOCO can be liable for rentals from the date
when it began to occupy the premises to the date it vacated it.
Held: NACOCO is not liable for rentals prior to the judgment. For
NACOCO to be liable at all, its obligations must arise from any of
the sources of obligations, namely law, contract or quasi-contract,
crime or negligence. NACOCO is not guilty of any offense at all,
because it entered the premises and occupied it with the
permission of the entity that had the legal control and
administration thereof, the Alien Property Custodian of USA.

Sagrada Orden v. National Coconut Corporation (1952)

SUMMARY: NACOCO is being sued for rentals for its occupation of warehouse by the owner,
Sagrada Orden. Sagrada Orden was registered owner before WW2. However, the property
was acquired by a Japanese Corporation during the Occupation. NACOCO gained possession
of the property from the Alien Property Custodian, which took control of properties belonging
to enemy nationals after the war. The Supreme Court held that NACOCO could not be liable
therefor, the alleged obligation to pay rentals not being hinged on law, contract, quasicontract, crime, or negligence.

FACTS:
x

Sagrada Orden owns a piece of land in Pandacan and the warehouse which stands on
it. Title to the property was registered in its name before WW2.

During the Japanese occupation, the land was acquired by Taiwan Tekkosho, a
Japanese corporation, for P140,000. As such, title was issued in its name.

After liberation, the Alien Property Custodian of the USA took possession, control, and
custody of the property, on the strength of the Trading with the Enemy Act, on the
ground that the property belonged to an enemy national.

Under a custodianship agreement with the Alien Property Custodian, the property
was later occupied by Copra Export Management Company, and then by the National
Coconut Corporation.

Sagrada Orden made a claim to the property before the Alien Property Custodian, but
this was denied.

So, Sagrada Orden brought an action against the Alien Property Custodian to annul
the sale of property to Taiwan Tekkosho, and recover its possession. The court
rendered judgment releasing the Alien Property Custodian and Philippine Government
from liability, and entitling Sagrada Orden the recovery of reasonable rentals from
NACOCO.

The present action is an action to recover such rentals covering the time NACOCO
occupied the premises.

NACOCO argued that it occupied the property in good faith, and under no obligation
to pay rentals for the use and occupation of the warehouse.

However, the court rendered judgment ordering NACOCO to pay Sagrada Orden
rentals, in the sum of P3000/ month. It ratiocinated that Sagrada Orden has always
been the owner of the property, as the sale to Taiwan Tekkosho was void.

ISSUE: WON NACOCO is liable for rentals to Sagrada Orden NO

RATIO:
If NACOCO is liable, its obligation must arise from any of the sources of obligations: law,
contract, quasi-contract, crime, or negligence.
x

Law The Court has tried in vain to find a law or provision thereof upon which the
claim can be supported.

Contract There was no privity of contract between the Alien Property Custodian and
Taiwan Tekkosho, such that the Alien Property Custodian or its permittee may be held
responsible for the supposed illegality of the occupation of the property. Also, there
was no agreement, not even implied, between the Alien Property Custodian and
NACOCO for the latter to pay rentals on the property. The Copra Export Management
Company, which preceded NACOCO, does not appear to have paid rentals therefor.
There was no provision in the custodianship agreement for the payment of rentals.

Quasi-contract The Court has tried in vain to find a principle in quasi-contracts or

equity upon which the claim can be supported.

Crime NACOCO is not guilty of any offense at all. It entered the premises and
occupied the property with the permission of the Alien Property Custodian.

Negligence There was no negligence on NACOCOs part.

As NACOCO entered into possession of the property without any expectation for such use
and occupation, it cannot be held liable therefor.
DISPOSITIVE: Lower courts ruling is reversed. NACOCO is not liable for rentals to Sagrada
Orden.

Alyanna Apacible B2015

Pichel vs. Alonzo 111 SCRA 341

digested by LLB 1-4 College of Law, Polytechnic University of the Philippines
Facts: This case originated in the lower Court as an action for the annulment of a
"Deed of Sale" dated August 14, 1968 and executed by Prudencio Alonzo, as
vendor, in favor of Luis Pichel, as vendee, involving property awarded to the former
by the Philippine Government under Republic Act No. 477. That the sale of the
coconut fruits are for all the fruits on the aforementioned parcel of land presently
found therein as well as for future fruits to be produced on the said parcel of land

during the years period; which shall commence to run as of SEPTEMBER 15,1968;
up to JANUARY 1, 1976.
In July 1972, defendant for the first time since the execution of the deed of sale in
his favor, caused the harvest of the fruit of the coconut trees in the land.
Issue: Whether or not the agreement in question is denominated by the parties as
a deed of sale of fruits of the coconut trees found in the vendor's land or it actually
is, for all legal intents and purposes, a contract of lease of the land itself?
Held: The Supreme Court ruled that construction or interpretation of the document
in question is not called for. A perusal of the deed fails to disclose any ambiguity or
obscurity in its provisions, nor is there doubt as to the real intention of the
contracting parties. The terms of the agreement are clear and unequivocal, hence
the literal and plain meaning thereof should be observed. Such is the mandate of
the Civil Code of the Philippines which provides that:
Art. 1370. If the terms of a contract are clear and leave no doubt upon the intention
of the contracting parties, the literal meaning of its stipulation shall control ... .
Pursuant to the afore-quoted legal provision, the first and fundamental duty of the
courts is the application of the contract according to its express terms,
interpretation being resorted to only when such literal application is impossible. 9
The provisions of the contract itself and its characteristics govern its nature. 4
Simply and directly stated, the "Deed of Sale dated August 14, 1968 is precisely
what it purports to be. It is a document evidencing the agreement of herein parties
for the sale of coconut fruits of Lot No. 21, and not for the lease of the land itself as
found by the lower Court. In clear and express terms, the document defines the
object of the contract thus: "the herein sale of the coconut fruits are for the fruits on
the aforementioned parcel of land during the years (from) SEPTEMBER 15, 1968; up
to JANUARY 1, 1976." Moreover, as petitioner correctly asserts, the document in
question expresses a valid contract of sale. It has the essential elements of a
contract of sale as defined under Article 1485 of the New Civil Code which provides
thus:
Art. 1458. By the contract of sale one of the contracting parties obligates himself to
transfer the ownership of and to deliver a determinate thing, and the other to pay
therefor a price certain in money or its equivalent.