Lease of building INCLUDES lease of land

In Duellome v. Gotico, petitioner leased his lot for P10.00 a month to private respondents' father-in-law, who later built a house on the land. When the lessee transferred residence to another place, private respondents were left in the house, which they rented from the lessee for P20.00. They paid P10.00 to the owner of the land and P10.00 to the owner of the house. Later, however, upon request of the lessee, private respondents paid the entire rent to the lessee. Because the rent on the land was not paid, the owner of the lot brought an ejectment suit against private respondents. The suit was eventually dismissed as the lessee paid the rents in arrears, but private respondents sued the owner of the lot for damages, claiming that the ejectment suit was malicious and caused damage to their reputation. They contended that they were not really liable to petitioner for the payment of the rent on the land. In absolving petitioner from liability for damages, this Court held that in a true sense private respondents were lessees of the land, and not only of the house because "[t]he lease of the building naturally include[s] the lease of the lot and the rentals of the building include the rentals of the lot." Since the lessee failed to pay the rents, the lot owner had a right to sue the private respondents as sublessees of the land for the unpaid rentals in accordance with Art. 1652 of the Civil Code. [G.R. No. 94516. December 6, 1996]