- Petitioner
- Donaldson
- Respondent
- Smith
- Citation
- G.R. No. 411
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ladd, J.
- Decided
- April 23, 1902
Summary
Donaldson, Sim & Co. sued Smith, Bell & Co. for damages allegedly sustained due to defendants' wrongful occupancy of warehouses from May 2-14, 1900. The warehouses, owned by Luis Yangco, were leased to plaintiffs on May 1, 1900, but defendants continued occupying them despite notice to vacate. The Supreme Court affirmed the lower court's decision in favor of defendants, ruling that plaintiffs failed to establish any legal relationship with defendants creating enforceable duties. Since plaintiffs never entered possession, they acquired no rights in rem against third parties. The Court distinguished this case from Civil Code provisions protecting actual lessees in possession, holding that plaintiffs' remedy lay against their lessor rather than the occupying defendants.
Intellegal Wiki · Key Holding
Affirmed the lower court, holding that a lessee who never entered into possession acquired no rights in rem enforceable against third persons; a lessee's direct action against a trespasser under Article 1560 applies only once actual interference with use has begun, and the plaintiffs' remedy lay against their lessor under Articles 1554 and 1556 (under the old Civil Code numbering).
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.