G.R. No. L-7048, January 12, 1912
THE MUNICIPALITY OF MONCADA, plaintiff-appellee, vs. PIO CAJUIGAN, ET AL., defendants-appellants.

FACTS

The Municipality of Moncada leased fish ponds to Pio Cajuigan for one year (July 1, 1908, to June 30, 1909) at a total rent of P3,710, payable quarterly. Cajuigan failed to pay the first two quarterly installments despite two extensions granted by the municipality, the last extending the deadline to November 30, 1908. Cajuigan claimed he tendered payment on November 30 and again on December 2, but the municipal treasurer refused acceptance. The municipality rescinded the lease on November 30 and forcibly evicted Cajuigan around December 6, 1908, seizing his fishing nets and corrals left on the premises. The municipality sued Cajuigan and his sureties for the full rent, penalties, and interest. Cajuigan counterclaimed for damages due to the eviction and loss of property.

ISSUE

1. Whether Cajuigan was liable for unpaid rent despite the eviction.
2. Whether the municipality’s eviction of Cajuigan entitled him to damages.
3. Whether the sureties were liable given the premature termination of the lease.

RULING

1. On rent liability: Cajuigan was liable for rent accrued up to the date of eviction (five months, not six), as eviction relieves the tenant only of future rent, not overdue amounts. Rent is compensation for possession; once possession ceases, the obligation to pay future rent stops. Thus, the municipality could recover P1,855 (five months’ rent) plus agreed penalties.
2. On damages for eviction: The municipality’s forcible eviction was a trespass, making it liable for damages equal to the value of Cajuigan’s seized property (P210). However, Cajuigan could not recover lost profits, as damages are limited to direct consequences of the trespass.
3. On sureties’ liability: The sureties remained liable because the action was filed after the lease term expired, and their obligation covered the lessee’s failure to pay rent due under the contract.
The trial court’s judgment was modified: The municipality could recover five months’ rent plus penalties, minus P210 for damages caused by the trespass. The sureties’ liability was upheld. Costs were imposed on appellants.