G.R. No. 222980 - Rodriguez vs. Park N Ride, Inc.

On August 16, 2000, Iloilo Jar Corporation (lessor) and Comglasco Corporation/Aguila Glass (lessee) entered into a lease contract covering a 450-sqm portion of a warehouse (Lot 2-G-1-E-2, Barangay Lapuz, La Paz District, Iloilo City).
The lease term was three years, expiring on August 15, 2003.

On December 1, 2001, Comglasco requested pre-termination of the lease, which Iloilo Jar denied. On January 15, 2002, Comglasco nevertheless removed its stocks and equipment and ceased paying rent.
After several demand letters (final demand on September 14, 2003) went unheeded, Iloilo Jar filed a breach-of-contract and damages suit before the RTC on October 10, 2003.

On June 28, 2004, Comglasco filed its Answer, invoking Article 1267 of the Civil Code (rebus sic stantibus) due to the economic crisis. Iloilo Jar moved for judgment on the pleadings on July 15, 2004.
By Order of August 18, 2004, the RTC granted judgment on the pleadings, holding that Article 1267 did not apply to lease (an obligation to give). A January 24, 2005 motion for reconsideration was denied.
In its February 17, 2005 Amended Order, the RTC awarded Iloilo Jar:

Comglasco appealed. On January 30, 2015, the CA reversed and remanded, finding that the Answer did tender an issue and that judgment on the pleadings was improper.
A June 17, 2015 CA resolution denied Iloilo Jar’s motion for reconsideration.

Iloilo Jar filed a petition for review on certiorari (filed one day late but granted under equity).
The SC considered the propriety of judgment on the pleadings versus summary judgment and the applicability of Article 1267.

Whether an inapplicable defense in an answer may properly be considered as tendering an issue requiring trial.
Whether judgment on the pleadings is appropriate and valid when the defense asserted is not applicable to the cause of action.