Allan Mañas v. Rosalina Roca Nicolasora

Summary

The Mañas Spouses leased property under a contract containing a right of first refusal clause. After the lease expired, they continued occupancy with rental payments, creating an implied month-to-month renewal. When the property was sold without offering it to them first, they filed for rescission claiming violation of their right of first refusal. The Supreme Court denied their petition, ruling that implied lease renewals under Article 1670 of the Civil Code only revive terms germane to the lessee's continued enjoyment of the property. The right of first refusal, being alien to possession, is not automatically included in implied renewals. The Court applied the Dizon v. Court of Appeals precedent, emphasizing that without express renewal, parties cannot presume revival of all original contract terms. This decision clarifies the limited scope of implied lease renewals and the distinction between terms essential to occupancy versus special contractual rights.