Regina P. Dizon v. Court of Appeals

Summary

This consolidated case involved a property dispute between landowners (Dizon family) and Overland Express Lines, Inc. regarding a lease with option to purchase. The lessee remained in possession after the one-year lease expired, creating an implied monthly renewal. Alice Dizon, without written authority, received P300,000.00 from the lessee as purported partial payment for property purchase. The Supreme Court ruled that no perfected contract of sale existed because: (1) Alice Dizon lacked written power of attorney required under Article 1874 of the Civil Code for land sales through agents; (2) the option to purchase expired with the original lease and was not revived in the implied renewal under Article 1670; and (3) implied lease renewals only incorporate terms germane to continued possession, not special agreements like purchase options. The Court ordered petitioners to refund the P300,000.00 received through Alice Dizon while maintaining that no binding sale contract was created.