Case Digest (G.R. No. 233678)
Facts:
In Cecilia Yulo Locsin, substituted by Leandro Y. Locsin, petitioner, versus Puerto Galera Resort Hotel, Inc. (PGRHI) and Luisito B. Padilla, respondents (G.R. No. 233678, July 27, 2022), the case arose from Padilla’s complaint for actual, moral, and exemplary damages against Cecilia for allegedly removing or destroying P12.5 million worth of fixtures and improvements in a hotel complex owned by Robustiniano Quinto, Jr. Quinto had leased the property to Padilla in 1993 with rights to improve it. In 2004, they signed a Memorandum of Agreement (MOA) to jointly market and share lease proceeds. In May 2006, acting under the MOA, they leased the complex to Cecilia for ten years at ₱90,000 monthly; she paid a ₱500,000 deposit, took possession, and paid rentals. A year later, Quinto found the premises gutted and reported damages to Padilla. Cecilia denied liability, claiming no perfected lease. Padilla, under a Special Power of Attorney (SPA) from Quinto dated August 28, 2007, filed thCase Digest (G.R. No. 233678)
Facts:
- Parties and Cause of Action
- Petitioners: Cecilia Yulo Locsin (substituted by Leandro Y. Locsin) vs. Puerto Galera Resort Hotel, Inc. (PGRHI), represented by Luisito B. Padilla, and Padilla in his own capacity.
- Complaint: Actual, moral, and exemplary damages with attorney’s fees and costs, for alleged looting and destruction of hotel fixtures and improvements.
- Contractual Background
- 1993 Lease: Quinto (owner) leased hotel complex to Padilla for 10 years; Padilla authorized to introduce improvements. Extended to 2013.
- October 15, 2004 MOA: Padilla and Quinto agreed to seek lessees, share rental earnings, and jointly protect their interests.
- May 2006 Lease to Cecilia: Pursuant to the MOA, Padilla and Quinto leased the complex to Cecilia for 10 years at ₱90,000/month; Cecilia paid ₱500,000 deposit, took possession, and paid rent.
- Damages and Procedural History
- 2007–2008 Events: One year later, Quinto found the complex vandalized; estimated loss ₱12.5 M. Demand letter sent; Cecilia denied a perfected lease.
- Complaint and Trial Court Proceedings: Padilla, PGRHI, and Quinto (via SPA) filed suit. Quinto later revoked SPA and moved to dismiss. Trial court granted dismissal, ruled no perfected lease, and awarded attorney’s fees to Cecilia.
- Court of Appeals: In April 2017, CA reversed RTC, held SPA irrevocable (agency coupled with interest), remanded for trial, and set aside attorney’s fees award. SC review ensued.
Issues:
- Whether Quinto effectively revoked the August 28, 2007 Special Power of Attorney (SPA) granting Padilla authority to sue.
- Whether Padilla is a real party-in-interest in the complaint for damages.
- Whether Cecilia is entitled to attorney’s fees and litigation expenses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)