Title
Sevilla vs. Court of Appeals
Case
G.R. No. L-41182-3
Decision Date
Apr 15, 1988
Lease dispute between Lina Sevilla and Tourist World Service over branch office management; SC ruled agency relationship, unlawful padlocking, and awarded damages for bad faith.

Case Digest (G.R. No. L-41182-3)

Facts:

  • Contract of Lease and Parties
    • On October 19, 1960, Mrs. Segundina Noguera (party of the first part) leased premises on A. Mabini St., Manila, to Tourist World Service, Inc. (TWS), represented by Eliseo S. Canilao (party of the second part).
    • Dr. Carlos L. Sevilla and Lina O. Sevilla (petitioners-appellants) were solidarily liable with TWS for timely payment of rent.
  • Branch Office Arrangement
    • TWS opened an Ermita branch office, operated by Lina O. Sevilla as “branch manager” in title only.
    • Airline commissions on bookings secured by Sevilla were split: 4% to Sevilla, 3% retained by TWS.
  • Events Leading to Dispute
    • On or about November 24, 1961, TWS learned Sevilla was connected with a rival firm; on December 2, 1961, its board (Exhs. 12 & 13) abolished the branch-manager office and authorized its corporate secretary to take over branch properties.
    • By letter of January 3, 1962, TWS terminated the lease (effective January 31, 1962) but ceased using the premises in November 1961; Sevilla continued operations thereafter.
    • On June 4, 1962, upon finding the premises locked and unable to contact Sevilla, Canilao padlocked the office “to protect TWS interests” and telephone lines remained disconnected.
  • Judicial Proceedings
    • Appellants filed a complaint for mandatory injunction and damages; respondents answered with counterclaims; the trial court dismissed both without prejudice, then reinstated Noguera’s counterclaim.
    • After refiling on June 17, 1963, the Court of First Instance dismissed appellants’ complaint and Noguera’s counterclaim for lack of merit.
    • The Court of Appeals affirmed. Petitioners then sought certiorari before the Supreme Court.

Issues:

  • Whether Tourist World Service, Inc. unilaterally disconnected the telephone line at the Ermita branch office.
  • Whether the padlocking of the premises by TWS and Canilao was an actionable wrongful self-help.
  • Whether the lessee of the Noguera premises was TWS alone or TWS jointly with Lina O. Sevilla.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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