Josie Go Tamio v. Encarnacion Ticson

Summary

This case involved a dispute over rental arrearages between a sublessee (petitioner Tamio) and sublessor (respondent Ticson) regarding an apartment owned by RCAM. Respondent subleased the property to petitioner based on an assignment from the previous lessee's daughter, but without RCAM's consent. When petitioner discovered RCAM's true ownership, she entered into a direct lease with RCAM covering the same period. The Supreme Court ruled that the assignment was invalid without the lessor's consent per Article 1649 of the Civil Code, and that requiring petitioner to pay both RCAM and respondent for the same period would constitute unjust enrichment. The Court applied equity to relax the estoppel rule that normally prevents lessees from challenging their lessor's title, emphasizing that justice requires preventing double payment for the same property use period.