G.R. No. L-10595; March 28, 1916
TEODORO KALAMBAKAL and PANTALEON DELGADO, plaintiffs-appellees, vs. VICENTE PAMATMAT, ET AL., defendants-appellants.

FACTS:
The Samahang Umu-unlad Association, an unincorporated civil association formed to operate a cockpit in Santa Cruz, Laguna, was placed under receivership upon the petition of a member. The Court of First Instance of Laguna appointed Teodoro Kalambakal and Pantaleon Delgado as receivers and ordered the association’s managing director, Martin Angeles, to deliver all association property to them. Angeles complied but withheld a contract of lease he had executed on May 1, 1912, in favor of Vicente Pamatmat and others, leasing the cockpit for P10 per month. The receivers did not recognize this lease as valid and took possession of the cockpit. When the defendants-lessees prevented the receivers from holding cockfighting mains, the receivers filed an action for injunction to restrain the defendants from interfering with their management and to recover possession.

The defendants claimed they were lawful lessees, having leased the property from Angeles, whom they alleged was authorized to do so. They argued the receivers were acting to favor a rival cockpit.

ISSUE:
Whether the plaintiff-receivers were entitled to a writ of injunction against the defendant-lessees to recover possession and management of the cockpit, thereby rendering the lease contract executed by the managing director after the receivers’ appointment unenforceable against them.

RULING:
Yes. The Supreme Court affirmed the trial court’s judgment granting a permanent injunction in favor of the receivers.

The Court ruled that the Samahang Umu-unlad Association, lacking articles of incorporation or by-laws, was a civil association governed by the majority vote of its members. The evidence showed that for important acts like leasing the cockpit, the managing director, Martin Angeles, historically convened the members for approval. There was no proof that the members authorized Angeles to execute the lease contract with the defendants dated May 1, 1912. Consequently, the lease contract was invalid and unenforceable against the association and its duly appointed receivers.

Furthermore, the receivers rightfully took possession of the association’s property by virtue of a court order dated May 20, 1912. Any act by Angeles after that date, including the disputed lease, could not bind the receivers. The defendants, therefore, had no right to occupy the cockpit and prevent the receivers from performing their duties. The receivers were entitled to the injunction to recover possession and manage the property for the benefit of the association in liquidation.

The Court also upheld the order for the defendants to pay indemnity for their use and occupation of the cockpit at the rate of P20 per month (the reasonable rental value), from May 20, 1912, until they vacate, with a deduction for days they were enjoined from operating.