G.R. No. L-32260 September 9, 1982
Raymunda Vda. De San Juan, et al., petitioners, vs. Sixto Tan, respondent.

FACTS

Jose San Juan, a co-owner of an untitled parcel of land, leased an 800-square-meter portion to respondent Sixto Tan for ten years, from May 1, 1967, to May 1, 1977. The lease contract included a stipulation for a three-meter right of way. Shortly after occupancy, Jose San Juan demanded a rental increase and, upon refusal, blocked the right of way. Tan filed a case for specific performance and damages. During its pendency, the other co-owners (petitioners) filed a motion to intervene, which was denied. They then filed a separate complaint for recovery of possession, arguing the lease by a single co-owner did not bind them.
The two cases were jointly pre-trialed and submitted for decision based on stipulated facts. The trial court dismissed the recovery of possession complaint, upheld the lease’s validity until May 2, 1977, ordered Jose San Juan to restore the right of way, and directed Tan to pay accrued rentals. Petitioners appealed, contending a co-owner cannot lease the entire property and bind others, and that the trial court made findings beyond the stipulations.

ISSUE

Whether the petitioners are entitled to recover possession of the leased property from the respondent.

RULING

Yes. The Supreme Court granted the petition and ordered the respondent to vacate and restore possession to the petitioners. The Court found it unnecessary to rule on the petitioners’ substantive arguments regarding the lease executed by a single co-owner. The legal logic turned on the contract’s explicit and finite term. The lease contract itself stipulated a period ending on May 1, 1977, and the trial court’s decision affirmed it was enforceable only “until May 2, 1977.”
Consequently, regardless of the lease’s initial validity or the co-ownership issues, the right to possess under the contract was definitively limited by its own terms. Upon the expiration of the agreed lease period, the lessee’s right to retain possession ceased. The respondent’s lawful occupancy, whether derived from a valid or voidable lease, was extinguished by the arrival of the contractual termination date. The petitioners’ action for recovery of possession thus became meritorious upon the lease’s expiration, entitling them to the return of the property. The Court ordered the respondent to vacate and pay all accrued rentals from 1968 until possession is restored.