G.R. No. 106427 - Inter-Asia Services Corp. vs. Court of Appeals

Petitioner: Inter-Asia Services Corp. (“Inter-Asia”); Respondents: Manila International Airport Authority (now Ninoy Aquino International Airport Authority, “NAIAA”) and the Court of Appeals’ Special Fifteenth Division.
On June 2, 1986, Inter-Asia and NAIAA entered into a lease contract allowing Inter-Asia to operate parking lots 1 and 2, and also to run a restaurant and food kiosk within the parking area.
The lease was for a period of four (4) years, commencing on July 14, 1986 and expiring on July 14, 1990, with a stipulation that renewal was at the option of the NAIAA.

As early as February 26, 1990, NAIAA informed Inter-Asia of its plan to improve the passenger arrival area through the construction of a multi-level parking facility on the leased premises.
Subsequent notices were given: on May 8, 1990 (approximately two months before lease expiration) regarding the segregation and occupation of a 9,000 square-meter portion of the parking area, and on June 7, 1990 (one month before lease expiration) indicating the intention not to renew the contract and to take over the area effective July 15, 1990.

Inter-Asia, in view of NAIAA’s repeated advisories, proposed an upgrading of its facilities and requested that the “status quo” be maintained while its proposal was under consideration.
NAIAA granted an extension that allowed Inter-Asia to operate the parking lots until January 31, 1991, later extended to March 31, 1991, before finally advising that effective April 1, 1991, the area would be taken over.
On March 27, 1991, Inter-Asia filed a complaint for specific performance and damages with a prayer for a writ of preliminary injunction, alleging that NAIAA was in violation of a contractual provision by threatening to eject the petitioner despite its operation of additional facilities.

The Regional Trial Court of Makati (Branch 61) under Judge Fernando V. Gorospe, Jr. issued a temporary restraining order and a writ of preliminary injunction on April 17, 1991, enjoining NAIAA from terminating or interfering with Inter-Asia’s operations pending the case.
NAIAA, through subsequent actions including filing a petition for certiorari, obtained from the Court of Appeals a temporary restraining order on June 26, 1991, which led to its taking possession of the premises.
The Court of Appeals later issued its own writ of preliminary injunction on July 19, 1991, enjoining Judge Gorospe from enforcing the RTC’s orders, and eventually rendered a decision on December 23, 1991 that directed Inter-Asia to vacate the premises pending further litigation.

Exceeding jurisdiction by deciding on the issue of possession, which is within the exclusive and original jurisdiction of the Metropolitan Trial Court under Rule 70 of the Rules of Court.
Grave abuse of discretion and a violation of substantive law and due process by granting injunctive relief without full trial and evidentiary hearing.
Improperly condoning NAIAA’s use of its temporary restraining order to recover possession.

Inter-Asia argued that despite alleged informal assurances of renewal and subsequent financial investments, the lease contract clearly provided that renewal remained at the option of NAIAA and that only definitive extensions (with specified dates) were granted, not an actual renewal.

The written lease contract stated that the term expired on July 14, 1990 and that renewal was solely at the option of NAIAA.
The extensions granted to Inter-Asia were expressly for a fixed additional period and did not constitute a renewal of the contract.
Consequently, the contract had ceased as of its fixed expiration date, leaving Inter-Asia without a legal right to continue possession.

Whether the Court of Appeals exceeded its jurisdiction by deciding on the issue of possession, an issue that is allegedly within the exclusive and original jurisdiction of the Metropolitan Trial Court under Rule 70 of the Rules of Court.

Whether the Court of Appeals gravely abused its discretion and violated substantive law and the constitutional right to due process by granting injunctive relief without the benefit of trial and proper evidentiary presentation.

Whether the trial court erred in issuing a writ of preliminary injunction that maintained the “status quo” by protecting Inter-Asia’s possession despite the expiration of its lease, thereby inadvertently condoning NAIAA’s act of taking over the leased premises.

Whether the extensions granted to Inter-Asia amounted to a renewal of the lease contract or merely an extension of the period, especially in light of the clear contractual provision that renewal was at NAIAA’s option only.