- Petitioner
- Efren S. Quesada
- Respondent
- Vardeleon Iii
- Citation
- G.R. No. 207500
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Brion, J.
- Decided
- November 14, 2016
Summary
This case involves a lease dispute between Bonanza Restaurants and Efren Quesada over a 9,404-square meter property in Quezon City. Bonanza filed an unlawful detainer case after unilaterally rescinding the lease contract, claiming Efren violated lease terms by constructing improvements and failing to include mandatory termination clauses in subleases. The MeTC initially dismissed the case for prematurity, but the RTC and CA reversed, ruling the lease was simulated and unenforceable. The Supreme Court granted the petition, finding that Bonanza's demand to vacate lacked legal basis since unilateral contract termination violates the mutuality of contracts principle. The Court held that none of the grounds for summary ejectment under Article 1673 of the Civil Code were present, and that the lower courts exceeded their appellate review scope by ruling on contract validity in a summary proceeding. The case demonstrates the importance of proper demand requirements in ejectment cases and the prohibition against unilateral contract termination.