G.R. No. L-26861 July 31, 1978
ERNESTO D. BOHOL, SR., and BOHOL CENTRAL COLLEGES, plaintiffs-appellants, vs. FRANCISCO L. TORRES, defendant-appellant.

FACTS

On May 15, 1960, defendant Francisco Torres leased a building in Manila to plaintiff Ernesto D. Bohol, Sr., for use as classrooms for Bohol Central Colleges. The lease was for three years. In April 1961, construction of a second story on an adjacent building, the Manila Recreation Hall owned by Torres’s son Renato, began. This construction seriously affected the natural light and ventilation of several classrooms in the leased building. Bohol brought this to Torres’s attention, and Torres proposed measures like installing skylights or air conditioning, but no agreement was reached. At Bohol’s request, the Bureau of Private Schools inspected the premises and found the building unfit for school purposes, subsequently advising the school’s closure.
On August 15, 1961, Bohol and the college filed an action for rescission of the lease and recovery of various damages. The trial court ordered Torres to pay damages for unrealized profits, improvements, guard salary, and attorney’s fees. Both parties appealed: the plaintiffs assailed the award as insufficient, while the defendant maintained he was not liable at all.

ISSUE

Whether the defendant-lessor, Francisco Torres, is liable for damages arising from the construction undertaken by his son on an adjacent property, which allegedly breached the warranty of peaceful and adequate enjoyment under the lease contract.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the complaint, holding the defendant not liable for damages. The Court clarified that the lessor’s obligation under Article 1654(3) of the Civil Code “to maintain the lessee in the peaceful and adequate enjoyment of the lease” is a warranty of legal possession, not a guarantee against all physical disturbances. Citing Goldstein vs. Roces, the Court explained that this obligation means the lessee shall not be disturbed in his legal right to possess, not that his physical enjoyment will be free from all inconvenience. The disturbance here was physical, not legal, as the lessor did not dispute Bohol’s right to occupy the premises.
Crucially, the Court found that the defendant was not the one who caused the disturbance; the construction was undertaken by his son, Renato Torres, who was not a party to the case. Furthermore, the evidence indicated that the plaintiffs’ own actions were the proximate cause of their alleged damages. The school was closed and tuition refunds began on June 13 or 14, 1961, before the Bureau of Private Schools’ closure order on June 26, 1961, and even before the adjacent construction was finished towards the end of June. The plaintiffs had requested the inspection specifically to obtain a basis for closing the school. Therefore, the damages claimed were a result of the plaintiffs’ own decisions, not a direct and proximate result of the lessor’s breach of any contractual obligation.