Mario S. Espina v. The Court of Appeals

Summary

This case involved a dispute over a condominium unit between landlord Mario Espina and tenant Rene Diaz. Diaz originally leased the unit in 1987, then entered into a Provisional Deed of Sale in 1991. When Diaz's postdated checks bounced, Espina cancelled the sale but continued accepting payments. The Supreme Court ruled that the provisional sale did not novate the original lease contract, as novation must be clearly proved and expressly agreed. The Court applied Article 1254 of the Civil Code, ruling that payments should be applied to the most onerous obligation (unpaid rentals). Consequently, Espina's unlawful detainer action was proper, and Diaz must vacate the premises and pay back rentals.