Case Digest (G.R. No. 125498) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves Privatization and Management Office (PMO) as petitioner and Firestone Ceramic, Inc. (FCI) as respondent. Under Republic Act No. 1160 and Executive Order No. 60 (1954), the Board of Liquidators administered a warehouse, Bodega 2, inside the National Development Company compound in Sta. Mesa, Manila, which had been leased to FCI and its predecessors since 1965. Executive Order No. 471 (2005) merged the Board into PMO, which thereafter managed the property. On October 11, 2006, PMO and FCI executed a two-year lease (January 1, 2006–December 31, 2008) at PHP 5,500/month with a renewal clause requiring written notice within sixty days before expiration and mutual agreement on new terms. FCI notified PMO on November 12, 2007 of its intention to renew and clarified on December 17, 2008 that the renewal would cover January 1, 2009 to December 31, 2011, but PMO responded on December 23, 2008 that it was conducting a market survey and would treat the lease on a month-to- Case Digest (G.R. No. 125498) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Lease Agreement
- Under Republic Act No. 1160 and Executive Order No. 60 (1954), the Board of Liquidators (BOL) was created to liquidate Land Settlement and Development Corporation assets, including “Bodega 2” (1,285 sq. m.) in NDC Compound, Sta. Mesa, Manila.
- Since 1965, the property was leased to Firestone Ceramic, Inc. (FCI) and its predecessors. Executive Order No. 471 (Nov. 17, 2005) merged BOL into the Privatization and Management Office (PMO), transferring administration.
- On October 11, 2006, PMO and FCI renewed the lease for Jan. 1, 2006–Dec. 31, 2008 at PHP 5,500/month, with a renewal clause requiring 60-day prior written notice and mutual agreement on terms.
- Renewal Negotiations and Lease Termination
- Nov. 12, 2007: FCI notified intent to renew Jan. 1, 2008–Dec. 31, 2009; Dec. 17, 2008: FCI sought Jan. 1, 2009–Dec. 31, 2011. PMO (Dec. 23, 2008) indicated continuation on month-to-month basis pending new lease.
- Feb. 11, 2009: PMO’s appraisal valued rent at PHP 20/sq. m. (PHP 25,700/mo). April 27, 2009: PMO offered PHP 35/sq. m. (PHP 44,975/mo), 15-day acceptance deadline.
- May 12, 2009: FCI counter-offered a 15% increase, three-year term. June 3, 2009: PMO rejected, terminated month-to-month lease, and demanded vacation within 30 days.
- Judicial Proceedings
- July 6, 2009: FCI filed Consignation/Specific Performance with TRO (RTC Pasay No. R-PSY-09-01071-CV); RTC denied TRO (July 23, 2009) but recognized renewed lease.
- Dec. 3, 2009: PMO filed Unlawful Detainer/Ejectment (MeTC Manila No. 186583-CV); MeTC (May 31, 2010) denied FCI’s Motion to Dismiss but held proceedings in abeyance pending RTC Pasay; August 11, 2010: denied reconsideration.
- Oct. 12, 2010: PMO filed certiorari in RTC Manila (No. 10-124494); May 7, 2012: RTC Manila granted petition and reversed MeTC abeyance orders; Sept. 3, 2012: denied reconsideration. FCI appealed to the Court of Appeals (CA).
- March 20, 2014: CA reversed RTC Manila, affirmed MeTC abeyance (Resolution Sept. 25, 2014). PMO filed a Rule 45 Petition for Review on Certiorari before the Supreme Court.
Issues:
- Whether the CA erred in ruling MeTC Manila lacked jurisdiction because PMO’s Verification and Certification Against Forum Shopping “converted” the unlawful detainer case into one for contract interpretation/enforcement.
- Whether the CA erred in affirming MeTC Manila’s suspension of unlawful detainer proceedings due to the pendency of FCI’s consignation and specific performance case before RTC Pasay City.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)