- Petitioner
- Leticia Elizondo Eupena
- Respondent
- Luis G. Bobier
- Citation
- G.R. No. 211078
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Carandang, J.
- Decided
- July 8, 2020
Summary
Eupena filed unlawful detainer against Bobier claiming ownership through TCT and lease contract. Bobier defended claiming he originally purchased the property from EDC and that Eupena obtained title through pactum commissorium via a Special Power of Attorney meant as loan collateral. Lower courts initially ruled for Eupena based on lease contract estoppel. However, the Court of Appeals and Supreme Court found that the circumstances indicated Eupena illegally appropriated the property when Bobier defaulted on his loan, constituting pactum commissorium prohibited under Civil Code Article 2088. The Supreme Court ruled the lease agreement was void as it resulted from the illegal appropriation, and Eupena failed to prove a valid lessor-lessee relationship necessary for unlawful detainer. The case demonstrates protection against creditors automatically appropriating collateral property upon debtor default.