Faustino Lichauco v. Tan Pho

Summary

This consolidated Supreme Court case involved the validity of a 20-year lease executed by guardians without judicial approval. The Court held that Civil Code Article 1548 requires judicial authorization for guardian-executed leases exceeding six years. Since no proper judicial approval was obtained, the lease was voidable as to the incapacitated ward and minors, though valid as to the co-lessor who was not under guardianship. The Court rejected nunc pro tunc orders attempting retroactive approval, finding insufficient basis in court records. Despite nullification, the lessee was deemed a good faith possessor entitled to ownership of improvements constructed. The decision established important precedents on guardian powers, nunc pro tunc requirements, and the effects of voidable contracts on third-party improvements, while ordering amendment of land registration records to reflect the partial nullification.