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MATAAS NA LUPA TENANTS ASSOCIATION V.

CARLOS
DIMAYUGA AND JULIANA DIEZ VDA. DE GABRIEL
G.R. NO. L-32049
JUNE 25, 1984
FACTS:
For more than ten years prior to 1959, the petitioners have been occupants of a parcel of land
(With their 110 houses built thereon 110 tenant families) formerly owned by Vda. de Gabriel to whom
petitioners have been paying their rents for the lease thereof, but who, on May 14, 1969, without notice
to petitioners, sold the same to respondent Dimayuga, who in turn mortgaged the same to her for the
balance of the purchase price. On the discovery of the sale the petitioner filed a complaint for the
exercise of their preferential rights before the CFI. And that pursuant to R.A. 1162, as amended by R.A.
2342 a parcel of land in Manila and suburbs, with at least 50 houses of tenants erected thereon and
actually leased to said tenants for at least 10 years prior to June 20, 1959, may not be sold by the land
owner to any person other than such tenants, unless the latter renounced their rights in a public
instrument. Their complaint also states that since the aforesaid contract of sale is expressly prohibited
by law, the same be declared null and void and for Vda. de Gabriel to execute a deed of sale in their
favor because they are likewise willing to purchase said land at the same price and on the same terms
and conditions observed in the contract of sale with respondent Dimayuga. On January 31, 1969,
respondent Vda. de Gabriel filed a motion to dismiss on the ground that the complaint is not a land
estate and not being such, the same cannot be expropriated and that no preferential rights can be
availed by the tenants.
On February 6, 1969, Dimayuga filed his answer admitting therein certain factual
allegations, denied some averments, interposed the affirmative defense that plaintiffs
had no personality to initiate the action, that the subject complaint stated no cause of
action against the respondent and prayed for the dismissal of the complaint and other
remedies. Plaintiffs filed their opposition to the motion to dismiss, maintaining that R.A.
1162, as amended by R.A. 2342 does not refer to landed estates, but to any piece of land occupied by
more than 50 families leasing the same for more than 10 years prior to June 20, 1959; that their
preferential rights is independent of the expropriability of the land; that therefore, said rights may be
exercised even if the land is not expropriable pursuant to the police power of the State for the general
welfare. On October 30, 1969, the CFI issued the subject order which found respondent's motion to
dismiss well-taken and thereby dismisses complaint. After a series of motions, reply, rejoinder,
surrejoinder, and answer between both parties, the lower court issued its order of May 11, 1970
dismissing petitioners appeal.
Petitioner thus resorted to this petition.
ISSUES:
1. Whether or not the contract of sale is null and void.
2. Whether or not the petitioners may invoke their preferential rights as tenants.
HELD:
The Court finds that the said sale was made illegally and therefore void. Also, the court finds
that the petitioners case falls within the law thus they may invoke their preferential rights as tenants.

PELAYO V. LAURON
12 PHIL 453
FACTS:
Petitioner Pelayo, a physician, rendered a medical assistance during the child delivery of the
daughter-in-law of the defendants. The just and equitable value of services rendered by him was
P500.00 which the defendants refused to pay without alleging any good reason. With this, the plaintiff
prayed that the judgment be entered in his favor as against the defendants for the sum of P500.00 and
costs.
The defendants denied all of the allegation of the plaintiff, contending that their daughter-inlaw had died in consequence of the child-birth, and that when she was alive, she lived with her husband
independently and in a separate house, that on the day she gave birth she was in the house of the
defendants and her stay there was accidental and due to fortuitous circumstances.
ISSUE:
Whether or not the defendants are obliged to pay the petitioner for the medical assistance
rendered to their daughter-in-law.
HELD:
According to Article 1089 of the Old Civil Code (now 1157), obligations are created by law, by
contracts, by quasi-contracts, by illicit acts and omissions or by those which any kind of fault or
negligence occurs. Obligations arising from law are not presumed. Those expressly determined in the
Code or in special law, etc., are the only demandable ones. The rendering of medical assistance in case
of illness is comprised among the mutual obligations to which the spouses are bound by way of mutual
support as provided by the law or the Code. Consequently, the obligation to pay the plaintiff for the
medical assistance rendered to the defendants daughter-in-law must be couched on the husband.
In the case at bar, the obligation of the husband to furnish his wife in the indispensable services
of a physician at such critical moments is especially established by the law and the compliance therewith
is unavoidable.

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