Case Digest (G.R. No. 142383)
Facts:
Asian Transmission Corporation v. Canlubang Sugar Estates, G.R. No. 142383, August 29, 2003, the Supreme Court Second Division, Callejo, Sr., J., writing for the Court.The dispute arose from a long-term lease: Canlubang Sugar Estates (CSE) owned a 50,000 sq.m. parcel in Canlubang Industrial Park; originally in 1972 CSE leased it to a joint venture that later organized as Asian Transmission Corporation (ATC). The parties executed an Adoption of Lease Agreement (effective July 1, 1973) and a 1991 Memorandum of Agreement (MOA) fixing annual rent through June 30, 1993 and providing for periodic rent reviews. The MOA set rental at P3,373,552.80 for July 1, 1991–June 30, 1992 and an 8% increase for July 1, 1992–June 30, 1993; no rent was fixed thereafter.
Negotiations in 1993 broke down when CSE proposed reducing leased area and increasing rent to P15,000,000. ATC rejected that proposal by letter dated October 11, 1993, tendered a different amount for 1993–1994 pending agreement, and offered alternatives (partial area return, buy-out). CSE treated ATC’s position as bad faith and on October 25, 1993 notified ATC of termination and demanded vacation. ATC filed for specific performance with damages and sought injunctive relief in the Regional Trial Court (RTC), Calamba (Civil Case No. 2052‑93‑C); CSE filed an unlawful detainer action in the Municipal Trial Court (MTC), Calamba (Civil Case No. 3215), seeking eviction.
The RTC issued TRO and preliminary injunction restraining the MTC from proceeding; after pretrial the RTC granted CSE’s motion for summary judgment on August 22, 1994, declaring CSE’s termination valid and dismissing ATC’s complaint. ATC appealed to the Court of Appeals (CA) in CA‑G.R. CV No. 45820; on January 16, 1996 the CA reversed and remanded for trial, ordering ATC to remain in peaceful possession pending resolution. Meanwhile the MTC proceeded and, on October 27, 1995, rendered judgment for CSE ordering ATC to vacate and to pay rentals; the RTC in an appeal (Civil Case No. 2247‑95‑C) affirmed with modification and ordered ATC to pay P15,000,000 per annum from July 1, 1993. ATC sought relief from the CA in CA‑G.R. SP No. 40757; on August 19, 1999 the CA affirmed the RTC and dismissed ATC’s petition. ATC’s motion for reconsideration was denied March 14, 2000.
While collateral proceedings on execution and related relief ensued, ATC filed a separate certiorari petition with the CA (CA‑G.R. SP No. 61722) challenging the RTC’s November 6, 2000 order granting execution; the CA granted that petition on January 23, 2001. CSE then filed a petition for review in this Court (G.R. No. 149211), which this Court denied on October 2, 2001 (final December 19, 2001). In the present Rule 45 petition (G.R. No. 142383) ATC challenged the CA’s August 19, 1999 Decision and March 14, 2000 Resolution, principally contesting (a) that the CA’s earlier ruling in CA‑G.R. CV No. 45820 was law of the case; (b) that ATC did not refuse to negotiate; and (c) that the award of P15,000,000 as reasonable compens...(Pro-only)
Issues:
- Is the allegation of forum shopping a bar to ATC’s present petition, given related petitions previously decided by the appellate courts and this Court?
- Are the questions whether ATC breached the lease and whether the lease was validly rescinded still justiciable, or are they moot and academic?
- Was the award of P15,000,000 per annum as reasonable compensation for ATC’s use and occupation from July 1, 1993 supported by the pleadings and evidence and prop...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)