G.R. No. 176986 - Nissan Car Lease Phils., Inc. vs. Lica Management, Inc.

Lica Management, Inc. (LMI) owns a 2,860 sqm property at 2326 Pasong Tamo Extension, Makati City.
On June 24, 1994, LMI and Nissan Car Lease Phils., Inc. (NCLPI) executed a 10-year lease (July 1, 1994–June 30, 2004) at P 308,000 monthly, with a 10% annual escalation.
NCLPI allowed its subsidiary, Nissan Smartfix Corp. (NSC), to use the premises.

NCLPI fell into arrears of P 1,741,520.85 by May 1996. The parties orally agreed to convert arrears into a promissory note and 12 postdated checks (June 1996–May 1997).
NCLPI delivered the checks but failed to sign the note or pay June–October 1996 checks.
On October 16, 1996 (sent October 18), LMI extrajudicially rescinded the lease for non-payment, demanded P 2,651,570.39, and required vacation within five days.

Proton Pilipinas, Inc. sought to display Audi cars for ten days; NCLPI executed a Memorandum of Agreement (Oct. 11, 1996) to allow renovations pending formal sublease.
On October 24, 1996, NCLPI acknowledged arrears but requested LMI to defer legal action, citing pending sublease talks.
LMI leased the property to Proton on November 8, 1996. On November 12, 1996, LMI sued NCLPI for P 2,696,639.97 plus damages.
NCLPI answered and filed a third-party complaint against Proton alleging collusion and sought P 3 million in damages. Proton counterclaimed for expenses and damages.

Whether a contract may be rescinded extrajudicially in the absence of an express contractual stipulation.
Whether, on the prevailing facts, LMI’s claims should be dismissed and NCLPI’s counterclaims granted.
The proper rate and computation of interest for delayed return of a security deposit in a lease contract.