Title
Tala Realty Services Corp. vs. Banco Filipino Savings and Mortgage Bank
Case
G.R. No. 132051
Decision Date
Jun 25, 2001
A lease contract dispute between Tala Realty Services Corporation and Banco Filipino Savings and Mortgage Bank leads to a Supreme Court ruling that the principle of "the law of the case" does not apply, upholding the validity of the lease contract and justifying Banco Filipino's eviction for non-payment of rent.
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Case Digest (G.R. No. 132051)

Facts:

  • The case involves Tala Realty Services Corporation and Banco Filipino Savings and Mortgage Bank concerning a lease contract dispute.
  • Tala was founded by four major stockholders of Banco Filipino: Antonio Tiu, Tomas B. Aguirre, Nancy Lim Ty, and Pedro B. Aguirre.
  • On August 25, 1981, Banco Filipino sold eleven branch sites to Tala and entered into lease agreements to lease them back.
  • The branch site in question is located in Iloilo City.
  • Tala initiated an illegal detainer action against Banco Filipino, asserting that the lease period had expired and rent was unpaid.
  • The Metropolitan Trial Court (MTC) ruled in favor of Tala, stating that an eleven-year lease contract superseded a prior twenty-year lease contract.
  • The MTC ordered Banco Filipino's eviction and mandated payment of back rentals totaling P79,050.00.
  • The ruling was upheld by the Regional Trial Court and affirmed by the Court of Appeals.
  • Banco Filipino sought reconsideration, referencing a prior ruling that validated the twenty-year lease contract.
  • The Court of Appeals agreed with Banco Filipino, stating that the earlier ruling constituted the "law of the case," prompting Tala to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Tala Realty Services Corporation.
  • The Court concluded that "the law of the case" did not apply, as the previous Court of Appeals decision was not a binding precedent due to its dismissal on technical grounds.
  • Banco Filipino could not be evicted based on lease expiration; however, its failure to pay rent since April 1994 justif...(Unlock)

Ratio:

  • The Supreme Court clarified that the doctrine of "stare decisis" was not applicable since the earlier ruling on the twenty-year lease was dismissed on technical grounds, not substantive issues.
  • The eleven-year lease contract presented by Tala was deemed a forgery due to improper execution and lack of necessary documentation, including failure to submit the contract to the Central Bank as requi...continue reading

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