QUINTOS VS BECK

FACTS: Quintos and Beck entered into a contract of lease, whereby the latter occupied the formers house.
On January 14, 1936, the contract of lease was novated, wherein Quintos gratuitously granted Beck the
use of the furniture , subject to the condition that Beck should return the furniture to Quintos upon
demand. Thereafter, Quintos sold the property to Maria and Rosario Lopez. Beck was notified of the
conveyance and was given 60 days to vacate the premises. In addition, Quintos required Beck to return
all of the furniture. Beck refused to return 3 gas heaters and 4 electric lamps since he would use them
until the lease is due to expire. Quintos refused to get the furniture since Beck had declined to return all
of them. Beck deposited all the furniture belonging Quintos to the sheriff.

ISSUE: Whether or not Beck complied with his obligation of returning the furniture to Quintos when he
deposited it to the sheriff.

RULING: The contract entered into between the parties is one of commadatum, because under it the
plaintiff gratuitously granted the use of the furniture to the defendant, reserving for herself the ownership
thereof; by this contract the defendant bound himself to return the plaintiff upon the latters demand
(paragraph 1 Article 1740 and Article 1741 of the Civil Code). The obligation voluntarily assumed by the
defendant to return the furniture upon the plaintiffs demand, means that he should return the same to
the plaintiff at the latters residence or house. The defendant did not comply with his obligation when he
merely placed them at the disposal of the plaintiff, retaining for his benefit the 3 gas heaters and 4 electric
lamps.

As the defendant had voluntarily undertaken to return all the furniture to the plaintiff, upon the latters
demand, the Court could not legally compel her to bear the expenses occasioned by the deposit of the
furniture at the defendants behest. The latter, as bailee, was not entitled to place the furniture on
deposit; nor was the plaintiff under a duty to accept the offer to return the furniture, because the
defendant wanted to return the three gas heaters and the 4 electric lamps.
CATHOLIC VICAR APOSTOLIC VS CA

FACTS: 1962: Catholic Vicar Apostolic of the Mountain Province (Vicar), petitioner, filed with the court an
application for the registration of title over lots 1, 2, 3 and 4 situated in Poblacion Central, Benguet, said
lots being used as sites of the Catholic Church, building, convents, high school building, school gymnasium,
dormitories, social hall and stonewalls.

1963: Heirs of Juan Valdez and Heirs of Egmidio Octaviano claimed that they have ownership over lots 1,
2 and 3. (2 separate civil cases)

1965: The land registration court confirmed the registrable title of Vicar to lots 1 , 2, 3 and 4. Upon appeal
by the private respondents (heirs), the decision of the lower court was reversed. Title for lots 2 and 3 were
cancelled.

VICAR filed with the Supreme Court a petition for review on certiorari of the decision of the Court of
Appeals dismissing his application for registration of Lots 2 and 3.

During trial, the Heirs of Octaviano presented one (1) witness, who testified on the alleged ownership of
the land in question (Lot 3) by their predecessor-in-interest, Egmidio Octaviano; his written demand to
Vicar for the return of the land to them; and the reasonable rentals for the use of the land at P10,000 per
month. On the other hand, Vicar presented the Register of Deeds for the Province of Benguet, Atty. Sison,
who testified that the land in question is not covered by any title in the name of Egmidio Octaviano or any
of the heirs. Vicar dispensed with the testimony of Mons. Brasseur when the heirs admitted that the
witness if called to the witness stand, would testify that Vicar has been in possession of Lot 3, for 75 years
continuously and peacefully and has constructed permanent structures thereon.

ISSUE: Whether or not Vicar had been in possession of lots 2 and 3 merely as bailee borrower in
commodatum, a gratuitous loan for use.

HELD: YES.

Private respondents were able to prove that their predecessors' house was borrowed by petitioner Vicar
after the church and the convent were destroyed. They never asked for the return of the house, but when
they allowed its free use, they became bailors in commodatum and the petitioner the bailee.

The bailees' failure to return the subject matter of commodatum to the bailor did not mean adverse
possession on the part of the borrower. The bailee held in trust the property subject matter of
commodatum. The adverse claim of petitioner came only in 1951 when it declared the lots for taxation
purposes. The action of petitioner Vicar by such adverse claim could not ripen into title by way of ordinary
acquisitive prescription because of the absence of just title.
DE LOS SANTOS VS JARRA (G.R. No. L-4150 February 10, 1910)

FACTS: The Plaintiff Felix delos Santos filed this suit against Agustina Jarra. Jarra was the administratix of
the estate of Jimenea. Plaintiff alleged that he owned 10 1st class carabaos which he lent to his father-in-
law Jimenea to be used in the animal-power mill without compensation. This was done on the condition
of their return after the work at the latters mill is terminated. When delos Santos demanded the return
of the animals Jimenea refused, hence this suit.

ISSUE: Whether or not the contract is one of a commodatum

HELD: YES. The carabaos were given on commodatum as these were delivered to be used by defendant.
Upon failure of defendant to return the cattle upon demand, he is under the obligation to indemnify the
plaintiff by paying him their value. Since the 6 carabaos were not the property of the deceased or of any
of his descendants, it is the duty of the administratrix of the estate to either return them or indemnify the
owner thereof of their value.

The Court of Appeals found that petitioner Vicar did not meet the requirement of 30 years possession for
acquisitive prescription over Lots 2 and 3. Neither did it satisfy the requirement of 10 years possession for
ordinary acquisitive prescription because of the absence of just title. The appellate court did not believe
the findings of the trial court that Lot 2 was acquired from Juan Valdez by purchase and Lot 3 was acquired
also by purchase from Egmidio Octaviano by petitioner Vicar because there was absolutely no
documentary evidence to support the same and the alleged purchases were never mentioned in the
application for registration.