- Petitioner
- Rosario Alzul
- Respondent
- Tutuban Properties
- Citation
- G.R. No. 168665
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Sereno, C.J.
- Decided
- July 22, 2015
Summary
The Alipio family leased commercial stalls at Tutuban Center Complex for selling ready-to-wear garments under a Product Zoning Scheme (PZS). When other tenants violated the PZS and respondent failed to consistently enforce it, petitioners sought rescission of their lease contracts claiming reduced sales. The RTC granted rescission and ordered return of priority premiums. However, the Court of Appeals and Supreme Court reversed, holding that PZS violations did not constitute substantial breach warranting rescission. The Supreme Court emphasized that rescission under Civil Code Article 1191 requires fundamental breaches defeating the contract's main object. Since the principal consideration was use of stalls for rental payments, and PZS was merely incidental, rescission was improper. The decision clarifies standards for contract rescission in commercial lease relationships.