- Petitioner
- Professional Academic Plans
- Respondent
- Dinnah L. Crisostomo
- Citation
- G.R. No. 148599
- Court
- Supreme Court
- Division
- Second Division
- Decided
- March 14, 2005
Summary
This case involves a contractual dispute over franchise commission between PAPI company officers and district manager Dinnah Crisostomo. Crisostomo successfully negotiated an AFPSLAI account and was granted franchise commission through company resolution, later reduced to 2% via written memorandum. When PAPI executed a new MOA with AFPSLAI, they stopped paying her commission and terminated her employment. The Supreme Court affirmed her entitlement to the commission based on estoppel principles, ruling that the original MOA was modified rather than cancelled, and that her written commission agreement remained valid. However, the Court deleted damage awards for lack of specific findings of bad faith, emphasizing that companies cannot unilaterally abandon contractual obligations without mutual consent under Article 1308 of the Civil Code.