PRIMITIVO ANSAY vs. NATIONAL DEVELOPMENT COMPANY,G.R. No. L-13667 April 29, 1960 Natural Obligations v.

Civil
Obligations

FACTS:

On July 25, 1956, appellants filed a complaint praying for a 20% Christmas bonus for the years 1954 and 1955.

The court a quo on appellees’ motion to dismiss, issued the following order:

The trial court dismissed the complaint and saying that the Court does not see how petitioners may have a cause of
action to secure such bonus because:

(a) A bonus is an act of liberality and the court takes it that it is not within its judicial powers to command respondents
to be liberal;

(b) Petitioners admit that respondents are not under legal duty to give such bonus but that they had only ask that such
bonus be given to them because it is a moral obligation of respondents to give that but as this Court understands, it has
no power to compel a party to comply with a moral obligation (Art. 142, New Civil Code).

(b) Petitioners admit that respondents are not under legal duty to give such bonus but that they had only ask that such
bonus be given to them because it is a moral obligation of respondents to give that but as this Court understands, it has
no power to compel a party to comply with a moral obligation (Art. 142, New Civil Code).

ISSUE: Whether or not there exists a cause of action in their complaint because their claim rests on moral grounds or
what in brief is defined by law as a natural obligation.

RULING: Article 1423 of the New Civil Code classifies obligations into civil or natural. “Civil obligations are a right of
action to compel their performance. Natural obligations, not being based on positive law but on equity and natural law,
do not grant a right of action to enforce their performance, but after voluntary fulfillment by the obligor, they authorize
the retention of what has been delivered or rendered by reason thereof”.

It is thus readily seen that an element of natural obligation before it can be cognizable by the court is voluntary
fulfillment by the obligor. Certainly retention can be ordered but only after there has been voluntary performance. But
here there has been no voluntary performance. In fact, the court cannot order the performance.

As held in the case of Philippine Education Co. vs. CIR and the Union of Philippine Education Co., Employees: From the
legal point of view a bonus is not a demandable and enforceable obligation. It is so when it is made a part of the wage or
salary compensation.

Premises considered, the order appealed from is hereby affirmed.

Case of Luis Pichel vs. Prudencio Alonzo

G.R.No. L- 36902 30January1982

FACTS:That Prudencio Alonzo (VENDOR) executed a deed of sale for the coconut fruits of his land in Balactasan
Plantation in Lamitan, Basilan, in favor of Luis Pichel (VENDEE). The land from which the subject coconut fruits are
derived from was subjected to a cancellation of the award in 1965, due to the reason of violation of the law that
disallows alienation of land (the vendor’s rights to the land were reinstated in 1972)
The vendor and his wife sold to the vendee the fruits of the coconut trees from 1968 to 1976 for consideration of 4,200.
Even during the date of sale, the land was still leased to one Ramon Sua, and it was part of the agreement of the sale
that the sum of 3,650.00 was to be paid by the vendor to Ramon Sua as to release the land.
The RTC decided in favor of the vendor, due to the fact that the deed of sale that was executed was invalid, due to its
supposed violation of RA No. 477, in which they equated the deed of sale executed by the parties as a contract of lease.

ISSUES: Was the Deed of Sale valid?

- Yes, The RTC erred in constructing the deed of sale as a contract of lease.
- There was no need on the part of the RTC to interpret the contract, since there was no ambiguity, it merely contracts
the sale of the fruits of the land, not the land itself.
- The S.C. relied upon ART 1370 of the Civil Code, regarding the rule on interpreting contracts.
- Its interpretation in express form is the preferred. Construction shall be employed when such literal interpretation is
impossible.
- The possession of the coconut fruits for 7 years is different from possession of the land, since the coconut fruits are
mere accessories and the land is the principal- a transfer of accessories does not necessarily mean a transfer of principal,
it is the other way around.
- The vendor after having received the consideration for the sale of his coconut fruits cannot be allowed to impugn the
validity of the contracts he entered into, to the prejudice of petitioner who contracted in good faith and consideration

HELD:The Judgment of the lower court has been set aside, and another one entered in its place, dismissing the
complaint.

Obligations and Contracts Terms:

• Difference between a contract of sale and a lease of things: that the delivery of the thing sold transfers ownership,
while in a lease no such transfer of ownership results as the rights of the lessee are limited to the use and enjoyment of
the thing leased.
• Contract of Lease- defined as giving or the concession of the enjoyment or use of a thing for a specified time and fixed
price.

SAGRADA ORDEN VS NACOCO G.R. NO. L-3756 JUNE 30, 1952

FACTS: The land in question belongs to plaintiff Sagrada Orden in whose name the title was registered before the war

On January 4, 1943, during the Japanese military occupation, the land was acquired by a Japanese corporation by the
name of Taiwan Tekkosho

After liberation on April 4, 1946, the Alien Property Custodian of the United States of America took possession, control,
and custody of the property pursuant to the Trading with the Enemy Act

The property was occupied by the Copra Export Management Company under a custodian agreement with US Alien
Property Custodian. When it vacated the property, it was occupied by defendant National Coconut Corporation

The plaintiff made claim to the said property before the Alien Property Custodian. Alien Property Custodian denied such
claim

It bought an action in court which resulted to the cancellation of the title issued in the name of Taiwan Tekkosho which
was executed under threats, duress, and intimidation; reissuance of the title in favor of the plaintiff; cancellation of the
claims, rights, title, interest of the Alien property Custodian; and occupant National Coconut Corporation’s ejection from
the property. A right was also vested to the plaintiff to recover from the defendants rentals for its occupation of the land
from the date it vacated.

Defendant contests the rental claims on the defense that it occupied the property in good faith and under no obligation
to pay rentals.

ISSUE: Whether or not the defendant is obliged to pay rentals to the plaintiff

HELD: No. Nacoco is not liable to pay rentals prior the judgment. If defendant-appellant is liable at all, its obligations,
must arise from any of the four sources of obligations, namley, law, contract or quasi-contract, crime, or negligence.
(Article 1089, Spanish Civil Code.) Defendant-appellant is not guilty of any offense at all, because it entered the premises
and occupied it with the permission of the entity which had the legal control and administration thereof, the Allien
Property Administration. Neither was there any negligence on its part.

PEOPLE’S CAR VS COMMANDO SECURITY G.R. L-36840 MAY 22, 1973

FACTS: People’s Car entered into a contract with Commando Security to safeguard and protect the business premises of
the plaintiff from theft, pilferage, robbery, vandalism, and all other unlawful acts of any person/s prejudicial to the
interest of the plaintiff.

On April 5, 1970, around 1:00am, defendant’s security guard on duty at plaintiff’s premises, without any authority,
consent, approval, or orders of the plaintiff and/or defendant brought out the compound of the plaintiff a car belonging
to its customer and drove said car to a place or places unknown, abandoning his post and while driving the car lost
control of it causing it to fall into a ditch.

As a result, the car of plaintiff’s customer, which had been left with plaintiff for servicing and maintenance, suffered
extensive damage besides the car rental value for a car that plaintiff had to rent and make available to its customer,
Joseph Luy, to enable him to pursue his business and occupation.

Plaintiff instituted a claim against defendant for the actual damages it incurred due to the unlawful act of defendant’s
personnel citing paragraph 5 of the contract wherein defendant accepts sole responsibility for the acts done during their
watch hours.

Defendant claimed that they may be liable but its liability is limited under paragraph 4 of the contract which provides
that its liability shall not exceed P1,000 per guard post for loss or damage through the negligence of its guards during the
watch hours provided that it is reported within 24 hours of the incident.

ISSUE: Whether or not the defendant is obliged to indemnify the plaintiff for the entire costs as result of the incident

HELD: Yes. Plaintiff was in law liable to its customer for the damages caused the customer’s car, which had been
entrusted into its custody. Plaintiff therefore was in law justified in making good such damages and relying in turn on
defendant to honor its contract and indemnify it for such undisputed damages, which had been caused directly by the
unlawful and wrongful acts of defendant’s security guard in breach of their contract.

Plaintiff in law could not tell its customer that under the Guard Service Contract it was not liable for the damage but the
defendant since the customer could not hold defendant to account for the damages as he had no privity of contract with
defendant.

Agcaoili vs. GSIS, 165

Facts: In this case, appellant GSIS approved an application of the appellee Agcaoli for the purchase of a house and lot in
the GSIS Housing Project at Nangka, Marikina, subject to the condition that the latter should forthwith occupy the
house, a condition that Agcaoli tried to fulfill but could not because the house was absolutely uninhabitable. However,
Agcaoli ask a homeless friend, a certain Villanueva, to stay in the premises as some sort of watchman, pending
completion of the construction of the house.

Agcaoli after paying the first installment and other fees, having thereafter refused to make further payment of other
stipulated installments until GSIS had made the house habitable; and appellant having refused to do so, opting instead
to cancel the award and demanded the vacation by Agcaoli of the premises; and the latter having sued the GSIS in the
Court of First Instance of Manila for specific performance with damages and having obtained a favorable judgment, the
cases was appealed by the GSIS.

Issue: Whether or not Agcaoli is entitled for specific performance with damages.

Held: Appeal of GSIS must fail.

There was then a perfected contract of sale between the parties; there had been a meeting of minds upon the purchase
by Agcaoli of a determinate house and lot from GSIS at a definite price which is payable in amortizations and from that
moment the parties acquired the right to reciprocally demand performance. It was, to be sure, the duty of the GSIS, as
seller, to deliver the thing soled in acondition suitable for its enjoyment by the buyer, in other words to deliver the
house subject of the contract in a reasonably livable state. This it failed to do.

Since GSIS failed to fulfill its obligation, and was not willing to put the house in a habitable state, it cannot invoke
Agcaoli’s suspension of payment as cause to cancel the contract between them. In recipient obligation, neither party
incur in delay of the other does not comply or is not ready to comply in a proper manner with what is incumbent upon
him. Nor may the GSIS succeed in justifying its cancellation of the award by the claim tha Agcaoli had not complied with
the condition of occupying the house within three (3) days. The record shows that Agcaoli did try to fulfill the condition.

Finally appellant having caused the ambiguity as the exact prestation of the agreement, the question of interpretation
arising therefrom, should be resolved against it.