SAGRADA vs. NATIONAL COCONUT CORPORATION, 93 Phil. 503, (1952).

Facts: Plaintiff Sagrada owned a parcel of land before the onslaught of World War II. During the time
Japanese forces occupied the Philippines, the land was forcibly acquired by a Japanese corporation,
Taiwan Tekkosho to which a land title was issued in its name. After the war, the Alien Property
Custodian of the USA took possession and control of the said land based on the Trading with the
Enemy Act. The land was then occupied by Copra Export Management, and when the same vacated
the premises, the land was occupied by the defendant National Coconut Corp. Plaintiff then made a
claim to repossess the land before the Alien Property Custodian of the US but this was denied. Thus, a
court proceeding ensued to annul the sale of the land made to Taiwan Tekkosho as it was void ab
initio for being made under duress. It was agreed that the title issued to Taiwan be canceled and the
same be re-issued to the plaintiff. It also ordered the defendant to vacate the premises of the land
owned by the plaintiff. Plaintiff now wants to recover reasonable rentals from the defendant from the
time they occupied the land to the time they vacated the same. The defendant then argued that it
occupied the land in good faith, and thus, they have no obligation to pay plaintiff rentals. The trial
court rendered judgment in favor of the plaintiff, ordering defendant to pay rentals, but not for the
entire period of their occupancy. Aggrieved, the instant petition is filed.

Issue: WON the trial court erred in holding defendant liable for the rentals not from the entire period
of their occupancy, but to only a period thereof.

Held: The trial court erred in ordering defendant to pay rentals to plaintiff at all. This is so because the
defendant occupied the premises under the permission of the US Government under the Trading with
the Enemy Act, who was then the legal owner of the land in which defendants occupied and that if at
all defendants were liable for rentals, it would not be awarded to the plaintiffs, but to the US
Government for they legally owned the land from the time the war ended to the time the title was
re-issued in plaintiffs name under the said Act. The defendant had no obligation whatsoever to pay
rentals to the plaintiffs. From the time defendant occupied of the land to the time it vacated the same,
the Alien Property Custodian had absolute control over the land with the power to sell or dispose of it,
as if it were the actual owner. There was also no agreement between the Alien Property Custodian
and defendant to pay rentals, so defendant had no obligation to pay rent for their occupancy of the
premises. Thus, the claim of plaintiff to be awarded rentals from defendant may not be predicated on
negligence or offense on their part, or any contract as the Alien Property Custodian was not a trustee
of the plaintiff, its title being based on a legal provision of the Trading with the Enemy Act.

Decision: The judgment appealed from is REVERSED.

HAMBON vs. COURT OF APPEALS AND CARANTES, G.R. No. 122150, March 17, 2003.

Facts: Petitioner filed a complaint for damages for the injuries he suffered after a collision with a truck
driven by respondent. Respondent argued that the complaint could no longer be pursued, as the
Criminal Case issued against him for the same act was dismissed and because petitioner failed to
make a reservation on the civil aspect of the case, then the same was impliedly instituted with the
criminal case and was thus also dismissed when the criminal case was also dismissed. The RTC ruled
that the civil case was not barred by the dismissal of the criminal case and petitioner is entitled to
damages. On appeal with the CA, the appellate court reversed the RTC ruling, stating that because the
petitioner failed to make a reservation to institute a separate civil case for damages, it was deemed
instituted in the criminal case and the dismissal of the criminal case also carried with it the dismissal
for the complaint of damages.

Issue: WON a civil action may be dismissed for failure of complainant to make a reservation to
institute a separate civil case, thus the civil case was deemed impliedly instituted with the criminal
case, and when the criminal case was dismissed, so was the civil action for damages.
Held: The petition must be denied. The amended rules on Criminal Procedure states that a party must
expressly reserve an action to institute a separate civil case for damages, otherwise, the same shall be
deemed impliedly instituted in the criminal case. Under the rule, civil actions to recover damages
arising from crime or quasi-delicts are deemed impliedly instituted with the criminal case unless
expressly waived, reserved or previously instituted. Prior reservation is an indispensable requirement
before an independent civil action can be instituted. Because petitioner Hambon failed to make a
prior reservation to his right to institute a separate civil case for damages, the same was deemed
impliedly instituted in the criminal case, and since that was dismissed, the Civil case for damages
subsequently filed by him without prior reservation should also be dismissed.

Decision: The instant petition is DENIED for lack of merit. The assailed CA decision is AFFIRMED.