W. H. Tipton v. Ramon Martinez y Andueza

Summary

This case involved a dispute over a 10-year lease of San Lazaro Hospital land executed by administrator Vicente Aguirre without special authority. The Supreme Court ruled that Article 1548 of the Civil Code, which limits administrators to 6-year leases without special power, applies to all administrators including public officials. The Court held the lease was partially valid - valid for 6 years but void for the remaining 4 years, as Aguirre exceeded his legal authority. The decision established that government administrators are subject to Civil Code limitations and cannot assume unlimited leasing power without express authorization. The ruling required return of property and accounting for rent and proceeds from the void period.