Manuel Rios v. Jacinto

Summary

This landmark 1926 Supreme Court case established the principle that when lessors voluntarily resume possession after a lessee's default, they elect rescission over specific performance, thereby abrogating the lessee's liability for future rent. The Court distinguished between two remedies available to lessors under Civil Code Articles 1124, 1555, and 1556: rescission with damages or specific performance with damages, but not both. Upon rescission, damages are limited to arrears and special damages from the default, not future rent obligations. The decision clarified that mere acquiescence in lease assignments does not constitute novation discharging the original lessee. This case significantly influenced Philippine jurisprudence on lease contract remedies and the doctrine of election between inconsistent remedies.