Title
Cuenco vs. Talisay Tourist Sports Complex, Inc.
Case
G.R. No. 174154
Decision Date
Jul 30, 2009
Petitioner sought deposit return after lease expiration; SC ruled respondents liable, deducting two months' arrears, denying repair claims, and adjusting interest rates.
A

Case Digest (G.R. No. 174154)

Facts:

  • Parties and contract
    • Jesus Cuenco (Petitioner) leased the Talisay Tourist Sports Complex from Talisay Tourist Sports Complex, Incorporated and Matias B. Aznar III (Respondents) for operation of a cockpit.
    • The original lease term was two years and was subsequently renewed for four years.
    • Petitioner delivered a deposit of Six Months' rental amounting to Five Hundred Thousand Pesos (P500,000.00) as security for damages during the lease.
  • Termination of lease and demand for return of deposit
    • The lease expired on May 8, 1998, after which a public bidding awarded the contract to a new lessee.
    • Petitioner demanded return of the deposit by four letters, all of which went unanswered.
  • Proceedings in the Regional Trial Court and Court of Appeals
    • Petitioner filed a complaint for sum of money, damages, and attorney's fees before the Regional Trial Court (RTC) of Cebu City.
    • The RTC ruled for petitioner and ordered respondents to return the full deposit plus interest of three percent (3%) per month from August 18, 1998 until full payment.
    • The Court of Appeals (CA) reversed the RTC.
  • Proceedings before the Supreme Court and October 17, 2008 decision
    • Petitioner filed a petition for review on certiorari under Rule 45, Rules of Court.
    • On October 17, 2008, the Court partly granted the petition, reversed and set aside the CA decision, and reinstated the RTC decision with modifications:
      • Talisay Tourist Sports Complex, Inc. was solely liable to return the deposit after deducting two months' arrears in rentals.
      • Legal interest was fixed at SIX PERCENT (6%) on the amount due from October 21, 1998, and TWELVE PER...(Subscriber-Only)

Issues:

  • Primary contested factual and legal questions
    • Whether petitioner overstayed for two months beyond the May 8, 1998 lease expiration, thereby incurring two months' rental arrears subject to deduction from the deposit.
    • Whether respondents may deduct repair expenses amounting to P24,900.00 from the deposit.
  • Procedural and appellate scope questions
    • Whether the Supreme Court should revisit or resolve factual findings made by the RTC and the CA.
    • Whether issues not raised during tria...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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