- Petitioner
- M. Goldstein
- Respondent
- Alejandro Roces
- Citation
- G.R. No. 8697
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Arellano, C.J.
- Decided
- March 30, 1916
Summary
This 1916 Supreme Court case established important precedent regarding lessor liability in lease relationships. Plaintiff operated a saloon in defendants' building and suffered business damages when construction authorized by defendants caused water leaks. The trial court initially ruled for plaintiff under Article 1554, but the Supreme Court reversed, holding that Article 1560 relieves lessors from liability for mere factual trespass by third parties. The Court distinguished between legal trespass (affecting lessor's title/right) which lessors must remedy, versus factual trespass (material interference) where lessees must pursue direct action against actual wrongdoers. This decision clarified the scope of lessors' duty to maintain peaceful enjoyment and established that continued physical occupation without legal challenge constitutes maintained peaceful enjoyment despite material disturbances.