Co-Tiongco v. Co-Guia

Summary

This 1902 Supreme Court case established that recorded lease contracts create real rights that bind subsequent purchasers of leased property. Co-Tiongco purchased a lot from Guidote in 1901, unaware of or disregarding a 10-year lease to Co-Quingco recorded in 1894. When Co-Tiongco sued Co-Guia (Co-Quingco's manager) for unlawful detainer, the Supreme Court reversed the lower court's favorable ruling. The Court held that recorded leases exceeding six years create enforceable rights against third parties under the Mortgage Law, and purchasers cannot terminate such leases without proper legal proceedings against the actual lessee. This decision reinforced the principles of property registration and protection of recorded real rights in Philippine jurisprudence.