G.Q. Garments v. Angel Miranda

Summary

G.Q. Garments leased property from Angel Miranda but was forcibly evicted by Florenda Miranda, who claimed prior lease rights based on a forged contract. G.Q. Garments sued for damages, claiming P10,000,000 in actual damages and seeking to hold Angel Miranda liable as lessor for breach of peaceful possession warranty. The Supreme Court denied the petition, ruling that G.Q. Garments failed to substantiate its damage claims with sufficient evidence beyond bare testimony. The Court held Angel Miranda not liable under Civil Code Articles 1654 and 1664, as Florenda's actions constituted mere trespass in fact rather than legal disturbance, making her solely liable to G.Q. Garments. The case clarifies that a lessor's duty to maintain peaceful possession extends only to legal possession, not protection from physical trespass by third parties, who must be sued directly by the lessee.