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G.R. No. 967, May 19, 1903, Eleizegui v. Lawn Tennis Club, 2 Phil 309 - ObliCon-CD

This document summarizes a Supreme Court case from the Philippines from 1903 regarding a land lease agreement dispute. The lower court had ruled that the lease duration depended on the will of the lessor, allowing them to terminate with one month's notice. However, the Supreme Court rejected this, noting the lease explicitly granted termination rights solely to the lessee. The Supreme Court instead applied a Civil Code article stating that when a contract's duration depends on one party's will, the courts have the authority to establish a reasonable term. Therefore, the Supreme Court ruled neither party could unilaterally determine the lease duration and instead directed the lower court to establish an equitable term.

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255 views1 page

G.R. No. 967, May 19, 1903, Eleizegui v. Lawn Tennis Club, 2 Phil 309 - ObliCon-CD

This document summarizes a Supreme Court case from the Philippines from 1903 regarding a land lease agreement dispute. The lower court had ruled that the lease duration depended on the will of the lessor, allowing them to terminate with one month's notice. However, the Supreme Court rejected this, noting the lease explicitly granted termination rights solely to the lessee. The Supreme Court instead applied a Civil Code article stating that when a contract's duration depends on one party's will, the courts have the authority to establish a reasonable term. Therefore, the Supreme Court ruled neither party could unilaterally determine the lease duration and instead directed the lower court to establish an equitable term.

Uploaded by

Marnil Magarao
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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G.R. No.

967, May 19, 1903 - 2 Phil 309


Dario and Gaudencio Eleizegui, plaintiffs-appellees, v. The Manila Lawn Tennis Club, defendant-appellant (lessee)
Arellano, C. J.

Facts:
 This case pertains to a legal dispute on a land lease agreement for a fixed payment, intended to last as long as the
lessee desires, with the lessee authorized to make improvements for the comfort and amusement of its members.
 The lease's duration became a point of contention, with three theories presented:
 One, relying on the lessor's will to terminate the lease with one month's notice,
 Second, on the lessee's will as stipulated, and
 Third, proposing the courts to fix the lease term.

Lower Court Ruling (RTC):


The court ruled in favor of the lessor Eleizegui, allowing the termination of the lease based on a notice given by the
plaintiff Eleizegui, aligning with the first theory that the duration depends on the will of the lessor.

Issue:
Whether or not the lease duration is determined by the will of the lessor, the lessee, or should be fixed by the courts.

Supreme Court Ruling:

The Supreme Court applied the doctrine concerning obligations with a term that is left to the will of one of the contracting
parties, specifically referencing Article 1128 of the Civil Code.

This article stipulates that when the duration of an obligation or contract is left to the discretion of the debtor (in this case,
the lessee Eleizegui), the courts have the authority to fix the duration of the term.

The Supreme Court rejected the first theory, which relied on Article 1581 of the Civil Code, because the lease contract
explicitly stated a duration dependent on the lessee's will, thereby making the application of a legal term irrelevant. The
Court also dismissed the idea that the lease could be terminated at the will of the lessor, as the contract specifically
granted termination rights solely to the lessee.

The Supreme Court ultimately ruled in favor of the third theory, emphasizing that the contract's term, left to the lessee's
will, should be determined by the courts as per Article 1128 of the Civil Code.

This decision emphasizes the principle that in cases where a contract's duration is contingent upon one party's will, it is
the judiciary's role to establish a reasonable term for the contract, ensuring fairness and preventing indefinite obligations.

Thus, the Supreme Court ruling directed a dismissal of the action for unlawful detainer and affirmed that the lease's
duration should not be unilaterally determined by either the lessor or the lessee but rather should be subject to the
judicial determination to establish an equitable term.

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