Case Digest (G.R. No. 172384) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Erminda F. Florentino v. Supervalue, Inc., petitioner Erminda Florentino, who operates a sole proprietorship under the trade name Empanada Royale, entered into three four-month renewable lease contracts on 8 March 1999 with respondent Supervalue, Inc., a corporation leasing commercial spaces in SM Malls. The leases covered two cart-type stalls at SM North EDSA and SM Southmall and one store space at SM Megamall, with combined security deposits totaling ₱192,000.00. After extending the leases until 31 March 2000, the respondent accused the petitioner, via two letters dated 14 January 2000, of breaching contractual obligations by failing to open on certain mall days, introducing a so-called “mini-embutido” empanada without approval, unilaterally raising prices, and closing early. The respondent notified the petitioner that it would not renew the leases and subsequently took possession of the Megamall space, confiscating equipment and personal belongings upon lease expiration. D Case Digest (G.R. No. 172384) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Lease Agreements
- Petitioner Erminda F. Florentino is a sole proprietor operating “Empanada Royale” with outlets in SM malls.
- Respondent Supervalue, Inc. is a domestic corporation leasing stalls and store spaces in SM malls nationwide.
- On March 8, 1999, the parties signed three four-month lease contracts (SM North Edsa, SM Southmall, SM Megamall) with P60,000 security deposit each, renewable by agreement.
- The leases were extended to March 31, 2000.
- Breaches, Non-Renewal and Seizure
- On February 4, 2000, respondent faxed two letters (both dated January 14, 2000):
- First letter cited breaches—failure to operate on December 16 & 26, 1999; sale of “mini-embutido” and price increase without approval; early closures—and warned of contract termination.
- Second letter informed petitioner of non-renewal effective March 31, 2000.
- Petitioner’s February 11, 2000 reply explained “mini-embutido” was merely a smaller empanada; respondent still refused renewal, repossessed SM Megamall premises and seized petitioner’s equipment and personal effects.
- Demand, Complaint and Lower Court Proceedings
- By May 8 and June 15, 2000 letters, petitioner demanded return of seized items and P192,000 security deposits; respondent refused.
- On August 17, 2000, petitioner filed Civil Case No. 00-1015 (Specific Performance, Money and Damages) in RTC Makati Branch 57, alleging:
- Verbal representation of renewable leases induced P200,000 improvements;
- Unjustified refusal to return P192,000 deposits;
- Illegal seizure of personal property.
- Petitioner prayed for actual damages (P472,000), moral (P300,000), exemplary (P50,000), attorney’s fees (P80,000).
- Respondent counterclaimed P106,474.09 for penalties and utilities, invoking its retaining lien for unpaid obligations; justified non-renewal due to breaches and forfeiture of deposits.
- Judgments and Appeals
- RTC Judgment (April 30, 2001) in favor of petitioner ordered:
- Payment of P192,000 security deposits and P50,000 attorney’s fees;
- Return of seized items after account settlement;
- Option to reimburse one-half value of improvements or require their removal.
- Respondent appealed to the Court of Appeals (CA).
- CA Decision (October 10, 2003) modified the RTC:
- Held forfeiture of deposits valid, no reimbursement for improvements, no attorney’s fees;
- Maintained order to return seized items.
- CA denied petitioner’s motion for reconsideration (April 19, 2006).
- Petitioner filed this Rule 45 petition before the Supreme Court.
Issues:
- Whether respondent is liable to return the P192,000 security deposits.
- Whether respondent must reimburse petitioner for improvements introduced in SM Megamall.
- Whether petitioner is entitled to attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)