Cjh Development Corporation v · G.R. 224006

Petitioner: Cjh Development Corporation
Respondent: Corazon D. Aniceto (And Vice Versa)
Citation: G.R. No. 224006
Court: Supreme Court
Division: Third Division
Ponente: Leonen, J.
Decided: July 6, 2020

Summary

This consolidated case involved the validity of lease contract provisions allowing extrajudicial ejectment and property seizure. CJH Development Corporation leased premises to Corazon Aniceto for her restaurant business. When the lease expired and continued on a month-to-month basis, CJH Development served notice to vacate. Despite Aniceto's court action seeking injunction, CJH Development demolished the restaurant and seized personal properties, invoking contractual authorization. The Supreme Court upheld the validity of extrajudicial ejectment clauses as resolutory conditions, but struck down provisions denying lessees reimbursement for improvements. The Court deleted damage awards, finding no abuse of rights, and ruled that deterioration of personal properties resulted from the lessee's unjustified refusal to retrieve them. This decision clarifies the enforceability of self-help remedies in lease contracts while maintaining Civil Code protections for lessees regarding improvements.

Statutes applied

Civil Code, Art. 1678

Related cases

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Sulo Sa Nayon v. Nayong Pilipino Foundation G.R. No. 170923
Samuel Parilla v. Dr. Prospero Pilar G.R. No. 167680
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By Intellegal Editorial Board · July 6, 2020

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