G.R. No. 427 : April 15, 1902
CO-TIONGCO, plaintiff-appellee, vs. CO-GUIA, defendant-appellant.

FACTS:
On March 6, 1894, Co-Quingco leased a lot from Pedro Sy-Quia (the purchaser) for ten years at a monthly rental of 50 pesos. Eugenio Guidote, the original vendor who reserved the right of redemption, bound himself to respect this lease. The contract was recorded in the property register on March 12, 1894. On January 23, 1901, Guidote sold the lot to Co-Tiongco by a public instrument, which was also recorded, declaring the property free from encumbrance. Co-Guia, acting as the manager of Co-Quingco’s lumber yard on the lot, consigned rental payments after Guidote and later Co-Tiongco refused to accept them. Co-Tiongco subsequently demanded that Co-Guia vacate the premises and filed an action for unlawful detainer, contending that Co-Guia was a mere month-to-month lessee. Co-Guia defended by presenting the recorded lease contract between Co-Quingco, Sy-Quia, and Guidote.

ISSUE:
Whether the action for unlawful detainer can be maintained by Co-Tiongco, the purchaser of the lot, against Co-Guia, based on the facts presented.

RULING:
No. The Supreme Court reversed the lower court’s judgment and dismissed the complaint. The recorded lease contract for a fixed term of ten years is a real right that binds not only the original parties but also third persons, including subsequent purchasers like Co-Tiongco, pursuant to the Mortgage Law. As a purchaser by singular title, Co-Tiongco is bound to respect the lease until its expiration in 1904, as the vendor Guidote could not convey a greater right than he possessed. The action for unlawful detainer against Co-Guia, who occupied the lot as manager/agent of the lessee Co-Quingco, will not lie. A judgment against Co-Guia would not affect the rights of the actual lessee, Co-Quingco, who was not a party to the suit. The proper remedy for Co-Tiongco, if he has a cause for rescission, is to seek judgment against Co-Quingco himself for the cancellation of the lease’s registration.