Short answer. No, not for that kind of loss. A lessee must return the thing leased as received, but the rule expressly excepts what is lost or impaired by the lapse of time, or by ordinary wear and tear, or from an inevitable cause — a typhoon destroying the property generally falls within that exception.
What the law says
save what has been lost or impaired by the lapse of time, or by ordinary wear and tear, or from an inevitable cause
Civil Code, Article 1665 — Return of the Thing Leased. Read the full provision →
The general duty to return the property as received
The starting rule is straightforward: the lessee shall return the thing leased, upon the termination of the lease, as he received it. That establishes the baseline expectation — you hand back what you were given, in the same condition you received it, unless the law itself carves out a specific exception to that particular duty in a given situation.
Three named exceptions to the return-as-received duty
The provision immediately qualifies that broad duty with the single word save, listing three specific causes of loss or impairment that are excused entirely: the lapse of time, ordinary wear and tear, and an inevitable cause. A typhoon, or a similarly destructive event genuinely beyond your control, is exactly the kind of occurrence the phrase 'inevitable cause' is meant to capture and excuse.
Why 'inevitable' is the key word
The exception is not for any damage you did not personally intend — it specifically covers loss from a cause that was genuinely unavoidable. A typhoon fits that description because it is an event outside human control that could not reasonably have been prevented, which is meaningfully different from damage arising instead from your own negligence, careless misuse, or a genuine failure to take reasonable care of the leased property while it was in your possession.
What this means for your position as lessee
Because loss from an inevitable cause is expressly excepted from the return-as-received obligation, you are not made to answer for that kind of loss simply because the property is no longer in its original condition when the lease ends. Whether a particular loss genuinely qualifies as inevitable, rather than something you could have reasonably foreseen, prevented, or otherwise contributed to yourself, is what actually decides whether this exception applies to your specific situation and the loss you experienced.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Agustin P. Dela Torre vs. The Hon. Court of Appeals, et al./Philippine Trigon Shipyard Corporation, et al. vs. Crisostomo G. Concepcion, et al, G.R. No. 160088 / G.R. No. 160565, July 13, 2011 — read the decision on LawPhil →
- University Physicians Services, Inc. vs. Marian Clinics, Inc. and Dr. Lourdes Mabanta, G.R. No. 152303, September 1, 2010 — read the decision on LawPhil →