Case Digest (G.R. No. 176986)
Facts:
Nissan Car Lease Philippines, Inc. v. Lica Management, Inc. and Proton Pilipinas, Inc., G.R. No. 176986, January 13, 2016, Supreme Court Third Division, Jardeleza, J., writing for the Court.
On June 24, 1994, Lica Management, Inc. (LMI) leased a Makati property to Nissan Car Lease Philippines, Inc. (NCLPI) for ten years (July 1, 1994–June 30, 2004) at a monthly rent of P308,000 with a 10% annual escalation. Shortly after, NCLPI allowed its subsidiary Nissan Smartfix Corporation (NSC) to use the premises. By May 1996 NCLPI was delinquent; rental arrears grew and by October 1996 amounted to several million pesos. NCLPI and LMI verbally agreed in May 1996 to convert certain arrears into a promissory note and twelve postdated checks, but NCLPI failed to sign the promissory note and failed to pay some of the checks for June–October 1996.
On October 16, 1996 (sent October 18, 1996 by registered mail), LMI notified NCLPI it was terminating the lease for nonpayment, demanded payment of P2,651,570.39 and ordered surrender within five days. Meanwhile, Proton Pilipinas, Inc. (Proton) sought temporary occupation and, by a Memorandum of Agreement dated October 11, 1996, was allowed to commence renovations and delivered a check representing three months’ rent to NCLPI, conditional on execution of a sublease. NCLPI acknowledged arrears by letter of October 24, 1996 and asked LMI to defer court action while negotiating a possible sublease. LMI executed a lease with Proton on November 8, 1996.
LMI filed suit on November 12, 1996 (RTC, Makati, Civil Case No. 96-1840) for unpaid rentals, damages, exemplary damages and attorney’s fees. NCLPI demanded Proton vacate (Nov. 20, 1996); Proton asserted a lease with LMI. NCLPI answered and filed a third‑party complaint against Proton alleging collusion to oust it and sought damages. The trial court admitted the third‑party complaint. Proton counterclaimed, alleging NCLPI misrepresented its status and had already surrendered possession to Proton, which had paid for temporary use and incurred renovation expenses.
On June 7, 2002, the Regional Trial Court (Branch 60, Makati) rendered judgment for LMI ordering NCLPI to pay unpaid rentals (with interest), exemplary damages and attorney’s fees, denied NCLPI’s third‑party complaint, and awarded Proton damages and fees. NCLPI appealed to the Court of Appeals (CA).
The CA, in a Decision dated September 27, 2006 (CA‑G.R. CV No. 75985), affirmed the trial court with modifications: it reduced exemplary damages and attorney’s fees, reduced the unpaid rental figure, and ordered return of a balance of the security deposit. The CA clarified (Resolution, March 8, 2007) that the reduced unpaid rental amount was inclusive of interest and penalties up to November 12, 1996, with 12% interest thereafter. NCLPI filed a Petition for Review on Certiorari (Rule 45) before the Supreme Court, raising, inter alia, whether extrajudicial resci...(Pro-only)
Issues:
- Was the petition procedurally defective because the Verification and Certification Against Forum Shopping was signed by Luis Manuel T. Banson without board authorization?
- May a lessor validly extrajudicially rescind a lease for lessee’s breach in the absence of an express contractual stipulation permitting extrajudicial rescission?
- Do the facts warrant dismissal of LMI’s claims and an award in favor of NCLPI for damages arising from alleged unlawful ouster?
- What interest rate and computation apply to (a) the unpaid ren...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)