Case Summary (G.R. No. 207500)
Background of the Case
The case involves a petition for review on certiorari filed by Efren S. Quesada and others following a decision by the Court of Appeals (CA) which affirmed a ruling by the Regional Trial Court (RTC) that reversed an earlier dismissal by the Metropolitan Trial Court (MeTC) regarding a complaint for unlawful detainer filed by Bonanza Restaurants, Inc. Bonanza is the registered owner of a property in Quezon City, which Efren, who was an employee of Bonanza, allegedly leased under a contract with terms favoring future subleasing.
Allegations and Legal Proceedings
Bonanza accused Efren of breaching the lease contract, primarily focusing on his failure to include a mandatory pre-termination clause in his subleases and constructing structures on the leased property without consent. Bonanza formally demanded, through a letter dated February 7, 2008, the return of the property, which Efren complied with only after receiving a subsequent demand directed to his sublessees. Consequently, Bonanza filed a complaint for unlawful detainer against Efren and the sublessees.
Decisions of Lower Courts
The MeTC initially dismissed Bonanza's complaint, determining that the lease had not been lawfully rescinded, and there was no established cause for action for ejectment. The MeTC held that Bonanza's unilateral cancellation of the lease was unjustified. Conversely, the RTC overturned the MeTC's decision, establishing that a case for unlawful detainer was valid given that Efren's refusal to vacate followed a formal demand.
Court of Appeals Ruling
The CA upheld the RTC's ruling, concluding that the allegations presented in Bonanza's complaint sufficiently established unlawful detainer, emphasizing that there was no requirement for Bonanza to file a separate rescission case prior to pursuing ejectment proceedings. The CA further found that the lease was not valid, as it lacked necessary corporate authority.
Arguments by Efren
In challenging the CA's decision, Efren invoked the doctrine of apparent authority, asserting that Bonanza had effectively ratified the lease by accepting rental payments over the years. He contended that the complaint for unlawful detainer failed to establish the requisite grounds for ejectment and that any dispute regarding the validity of the lease could only be resolved through a full trial, not through a summary proceeding.
Bonanza's Counterarguments
Bonanza rebutted by arguing that the doctrine of apparent authority was inapplicable as Efren was not a third party but an officer of the corporation, thus lacking standing. It maintained that it had laid out sufficient grounds for unlawful detainer, notably Efren's refusal to vacate after a demand.
Supreme Court Findings
Ultimately, the Supreme Court found merit in Efren's petition.
...continue readingCase Syllabus (G.R. No. 207500)
Case Overview
- This case involves a petition for review on certiorari filed by Efren S. Quesada and others against Bonanza Restaurants, Inc.
- The petition seeks to contest the January 16, 2013 decision and June 5, 2013 resolution of the Court of Appeals (CA) in CA-G.R. SP No. 122063, which affirmed the decision of the Regional Trial Court (RTC) in Civil Case No. Q-11-69040.
Parties Involved
- Petitioners: Efren S. Quesada, Peter Chua, Arturo B. Perejas, Erlinda Escota, Crisanto H. Lim, Vasquez Building Systems Corporation, Lion Granite Construction Supply Corporation, Nellie M. Mariveles, Alejandro V. Vardeleon III, Angelita P. Roque, David Lu, J.A.O. Builders & Development Corporation.
- Respondent: Bonanza Restaurants, Inc.
Background Facts
- Bonanza Restaurants, Inc. owns a 9,404-square meter property in Balintawak, Quezon City, covered by Transfer Certificate of Title No. RT-65703.
- Efren S. Quesada was employed as Bonanza's General Property Manager in 2003, and his brother Miguel served as the Company President.
- On July 1, 2003, Bonanza allegedly leased the property to Efren, with stipulated terms including a 60-day pre-termination clause for subleasing agreements.
Lease Agreement and Subsequent Events
- Efren entered into multiple subleases utilizing the lease contract.
- On February 7, 2008, Bonanza rescinded the lease and demanded the return of the property.
- Bonanza formally notified Efren's sublessees about the rescission of the lease on February 11, 2008.
- On March 26, 2008, Bonanza