Rafael Enriquez v. A. S. Watson & Co.

Summary

Estate administrator Rafael Enriquez sued Watson & Co. for additional rent, claiming lease agreements were invalid and seeking 12,800 pesos difference between reasonable property value and amounts paid. Watson & Co. occupied estate property as drug store under two lease agreements and paid all required rent. The Supreme Court reversed the lower court's judgment favoring the plaintiff, holding that subsequent conduct between parties made the 1900 ejectment judgment ineffective and Watson & Co. remained valid tenants. The Court applied Article 1548 of the Civil Code, ruling the January 1901 lease was valid for six years despite being made for a longer term. No evidence of fraud was found in the lease agreements, and Watson & Co. was absolved from liability.