Title
Tan vs. Planters Products, Inc.
Case
G.R. No. 172239
Decision Date
Mar 28, 2008
A dispute arises between Conchita Tan and Planters Products, Inc. over the renewal of lease contracts, leading to a legal battle where the Supreme Court rules that the failure to agree on all terms and conditions prevents the execution of new lease contracts.
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Case Digest (G.R. No. 172239)

Facts:

  • The dispute involves Conchita Tan (Marman Trading) and Planters Products, Inc. (PPI) regarding the renewal of lease contracts for sulfuric acid and ammonium tanks in Limay, Bataan.
  • The contracts, dated April 27, 1992, and June 10, 1992, had a ten-year term with an option for renewal based on mutually agreed terms.
  • On December 4, 2001, Marman expressed an intent to renew the leases and proposed renewal terms.
  • PPI responded with changes to the lease period, fees, escalation rate, and minimum volume requirements.
  • Marman accepted the commercial terms but not the non-commercial conditions such as pipeline relocation and facility repairs.
  • PPI refused to renew, alleging Marman's contract violations.
  • Marman filed a specific performance complaint with the RTC in Makati, which ruled in Marman's favor, directing PPI to execute new leases.
  • PPI appealed to the CA, which reversed the RTC's decision, prompting a petition to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that PPI's minor procedural defect (lack of page references in the appellate brief) did not warrant appeal dismissal.
  • The Supreme Court affirmed the CA's decision that the parties had not agreed on all renewal lease terms; thus, no ...(Unlock)

Ratio:

  • The Supreme Court emphasized that rigid application of procedural rules should not impede substantial justice.
  • The absence of page references in PPI's appellate brief was considered a minor defect that did not affect the case's merits.
  • The renewal clause in the original leases required mutual agre...continue reading

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