Title
Makati Water, Inc. vs. Agua Vida Systems, Inc.
Case
G.R. No. 205604
Decision Date
Jun 26, 2019
Franchise agreements expired; MWI continued operations, violating terms. AVSI sued for damages, closure, and repurchase. SC ruled termination includes expiration, upheld damages, but deleted indefinite closure.

Case Summary (G.R. No. 229928)

Facts and Antecedent Proceedings

Makati Water, Inc. entered two Franchise Agreements with Agua Vida Systems, Inc. to operate water refilling stations in Las Piñas City and Makati City. These agreements, effective for five years, included stipulations regarding the repurchase of equipment and non-competition clauses following termination. The parties did not renew the franchises upon expiration. Agua Vida Systems subsequently filed complaints for specific performance and damages when Makati Water operated the stations under its own name post-expiration, potentially violating the agreements.

Court Proceedings

The Regional Trial Court (RTC) denied a motion to dismiss MWI's case, determining the right to repurchase under the Franchise Agreements could not be exercised beyond four years from their execution. The court ruled in favor of AVSI for closure of the stations and awarded compensatory and exemplary damages as well as attorney's fees to AVSI. MWI filed for reconsideration which was denied. Appeals ensued leading to decisions by both RTC Branch 67 and eventually the Court of Appeals (CA).

Ruling and Legal Interpretation

The core issue in the petition revolves around the interpretation of “termination” within Section IV-5 of the Franchise Agreements, specifically whether it encompasses expiration. The Court concluded that “termination,” as described in the agreements, does include expiration, therefore MWI was obliged to cease operations within two years of the franchise's expiration, consistent with AVSI’s protective interest in its brand and goodwill.

Decision on Damages and Legal Basis

The Court affirmed the RTC’s findings regarding compensatory damages, citing evidence from AVSI regarding lost profits stemming from MWI’s continued operations. The amount awarded was substantiated by sales data for the two-year period following expiration. The Court emphasized the lawful entitlement of AVSI to damages due to MWI’s contravention of the prohibition clause.

Conclusion on Attorney’s Fees and Costs

Further, the CA modified the attorney’s fees awarded by

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