Sagrada Orden de Predicadores del Santisimo Rosario Filipinas vs. National Coconut Corporation [91 SCRA 503 G.R. No.L-3756 June 30, 1952]Post undercase digests,Civil LawatTuesday, March 20, 2012Posted bySchizophrenic MindFacts: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, quasi-contract, crime, or negligence.

FACTS: 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. 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 341digested by LLB 1-4 College of Law, Polytechnic University of the PhilippinesFacts: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. 4Simply 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.