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  • 050 - Villaroel vs. Manila Motor Co. 104 Phil 926

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    The document summarizes the 1958 Supreme Court case Villaruel vs. Manila Motor Co. Inc. It discusses the legal principle of mora accipiendi, which refers to the delay of the creditor in accepting payment. The case involved a lease agreement between Villaruel and Manila Motor for commercial and residential properties. When the properties were later destroyed by fire, the Court ruled that the lessor was liable because their refusal to accept current rental payments without also demanding back rent placed them in default under the principle of mora accipiendi.

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    The document summarizes the 1958 Supreme Court case Villaruel vs. Manila Motor Co. Inc. It discusses the legal principle of mora accipiendi, which refers to the delay of the creditor in accepting payment. The case involved a lease agreement between Villaruel and Manila Motor for commercial and residential properties. When the properties were later destroyed by fire, the Court ruled that the lessor was liable because their refusal to accept current rental payments without also demanding back rent placed them in default under the principle of mora accipiendi.

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    181 views2 pages

    050 - Villaroel vs. Manila Motor Co. 104 Phil 926

    Uploaded by

    AP Cruz
    The document summarizes the 1958 Supreme Court case Villaruel vs. Manila Motor Co. Inc. It discusses the legal principle of mora accipiendi, which refers to the delay of the creditor in accepting payment. The case involved a lease agreement between Villaruel and Manila Motor for commercial and residential properties. When the properties were later destroyed by fire, the Court ruled that the lessor was liable because their refusal to accept current rental payments without also demanding back rent placed them in default under the principle of mora accipiendi.

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    TITLE: Villaruel vs. Manila Motor Co. Inc.

    , 104 Phil 926 (1958)


    TOPIC: Mora Acciepiendi – Effects
    PRINCIPLE: Mora Accipiendi – Delay on the part of the creditor; The lessor’s refusal to
    accept the current rentals without qualification placed them in default (mora creditoris or
    accipiendi) with the result that thereafter, they had to bear all supervening risks of
    accidental injury or destruction of the leased premises. 
    FACTS:
    Villaruel and Manila Motor Co. Inc. entered into a contract whereby, the former agreed
    to convey by way of lease to the latter of the three premises:
    1. 500 sqms of floor space of a building of strong materials for automobile
    showroom offices, and store room for automobile spare parts;
    2. Building of strong materials for automobile repair shop; and
    3. 5-bedroom house of strong materials for residence of the Bacolod Branch
    Manager of the Motor Company.
    The lease term was five years from the time that the building was delivered and placed
    at the disposal of the lessee company, ready for immediate occupancy. The contract
    was renewable for an additional period of five (5) years.

    The Manila Motor Co agreed to pay the lessors a monthly rental of P300.00 payable in
    advance before the fifth day of each month and for the residential house of its branch
    manager, a monthly rental not to exceed P50.00 pesos payable separately by the
    Manager.

    Manila Motor Co. occupied the premises until the property was held by the Japanese
    forces from 1941 to March 29, 1945 and no payment was made during those time. The
    American forces later occupied the properties and the rentals were paid by the
    occupants at the same rate. When the American forces left, the branch manager
    decided to extend the lease for another 5 years and they agreed that the 7-month
    occupied by the American forces will not be counted as part of the extension of the
    lease term.

    Villaruel demanded payment for the period occupied by the Japanese forces. The
    company refused to pay and a notice for recission of contract of lease was given to
    them.

    The lessors accepted payment of current rentals from October 1945 to June 1946. It
    was only in July 1946 that they insisted upon collecting also the 1942-1945 rents, and
    refused to accept further payments tendered by the lessee unless their right to collect
    the occupation rental was recognized or reserved. 

    Grey offered to pay Villaruel the amount of P350.00 provided that it was without
    prejudice to the latter’s previous demand for rent in arrears and for the recission of the
    contract of lease.

    The lessors commenced an action against the company. During the pendency of the
    case, the leased property was burned down. As such, Villaruel demanded
    reimbursement from the defendants who refused to pay.

    ISSUE:
    WON the defendant company is liable for the loss of the leased premises.

    RULING:
    No. The Court ruled that the improper refusal of the lessor to accept the current rents
    tendered by the lessee placed them in default, thus, the former shall shoulder the
    subsequent accidental loss of the premises leased.

    Accordingly, the lessor' insistence upon collecting the occupation rentals for 1942-1945
    was unwarranted in law. Hence, their refusal to accept the current rentals without
    qualification placed them in default with the result that thereafter, they had to bear all
    supervening risks of accidental injury or destruction of the leased premises.

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