Petitioner
Felicidad Lopez
Respondent
Marciana Constantino
Citation
G.R. No. 48882
Court
Supreme Court
Division
First Division
Ponente
Ozaeta, J.
Decided
March 17, 1943

Summary

This case involves a property sale between mother and daughter with a life pension condition requiring payment of half the rental income to the vendor. When the buildings were destroyed by fire, the vendee sought to cancel the life pension obligation annotation on her title. The Supreme Court reversed the trial court, holding that the life pension obligation survived the building's destruction because the land itself has rental value and was part of the sale consideration. The Court applied Civil Code provisions on usufruct, ruling that even if the obligation attached only to the building, the usufructuary (appellant) retained rights to the land under Article 517. The decision establishes that contractual obligations tied to property rentals are not automatically extinguished when buildings are destroyed, as land retains independent rental value and potential for future development.

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By the Intellegal Editorial Board · March 17, 1943

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