Case Digest (G.R. No. 103068) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Meat Packing Corporation of the Philippines v. The Honorable Sandiganbayan, MPCP, a government‐owned corporation under the GSIS, owned a meat processing plant and three parcels of land in Barrio Ugong, Pasig City. On November 3, 1975, MPCP and Philippine Integrated Meat Corporation (PIMECO) entered into a lease‐purchase agreement for twenty‐eight years, with annual rentals of ₱1,375,563.92. The contract contained a rescission clause providing automatic cancellation upon nonpayment of rentals equivalent to three cumulative annual installments. A supplementary agreement on the same date increased the total contract price and raised the annual rental to ₱3,346,269.70, effective January 1, 1981. On March 17, 1986, the Presidential Commission on Good Government (PCGG) sequestered PIMECO’s assets, including the plant and the lease agreement. MPCP, alleging arrears exceeding ₱2,000,000 for 1986, notified PIMECO on November 17, 1986 of the rescission of the lease. The PCGG denied MPC Case Digest (G.R. No. 103068) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contractual Background
- Meat Packing Corporation of the Philippines (MPCP), wholly owned by GSIS, owns a meat‐packing plant and land in Ugong, Pasig.
- On November 3, 1975, MPCP and Philippine Integrated Meat Corporation (PIMECO) entered a lease-purchase agreement: annual rent ₱1,375,563.92 over 28 years (total ₱38,515,789.87), with automatic rescission if three installments unpaid; supplementary agreement increased total to ₱93,695,552.59, annual rent ₱3,346,269.70 from January 1, 1981.
- Sequestration and Rescission Notices
- March 17, 1986: PCGG sequesters all PIMECO assets, including the lease and plant.
- November 17, 1986: MPCP notifies PIMECO of rescission for arrears > ₱2 million in 1986; GSIS request to exclude the plant from sequestration denied by PCGG.
- PCGG resolutions (Sept. 20, 1988; Jan. 24, 1989) conditionally turn plant over to GSIS/MPCP upon Sandiganbayan approval and MOA.
- Sandiganbayan Civil Case No. 0024 (Sequestration Case)
- July 29, 1987: PCGG files complaint in Sandiganbayan for reconveyance and damages against PIMECO owners.
- 1989 interim resolutions: TRO (June 2), writ of preliminary injunction (July 10), amended injunction (Aug. 3) enjoin PCGG from turning over management of PIMECO to MPCP.
- November 29, 1989: Sandiganbayan declares PCGG turnovers null and void ab initio and permanently enjoins enforcement.
- Proceedings on Tender and Consignation; Civil Case No. 0108
- PCGG tenders ₱5,000,000 (two checks) on Jan. 30, 1991 for accrued rentals; MPCP refuses, citing prior rescission.
- July 2, 1991: Sandiganbayan orders MPCP to accept payment and issue receipt.
- November 29, 1991: Sandiganbayan denies MPCP’s motion for reconsideration, upholds valid tender/consignation to prevent automatic rescission.
- MPCP files petition for certiorari, mandamus, and prohibition before the Supreme Court.
Issues:
- Jurisdiction
- Whether Sandiganbayan had jurisdiction over MPCP, a non‐party to Civil Case No. 0024.
- Validity of Rescission
- Whether MPCP effectively rescinded the lease-purchase agreement upon PIMECO’s default.
- Tender and Consignation
- Whether PCGG’s tender of ₱5,000,000 and judicial consignation were valid and extinguished arrears.
- Effect on Lease Status
- Whether the valid consignation reduced arrears below three-installment threshold, preventing automatic cancellation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)