Iloilo Jar Corporation v. Comglasco Corporation/Aguila Glass

Summary

Supreme Court resolved a lease contract dispute between Iloilo Jar Corporation and Comglasco Corporation, clarifying important procedural and substantive law principles. Comglasco abandoned leased premises claiming economic crisis justified termination under Article 1267 of Civil Code. The Court distinguished judgment on pleadings from summary judgment, ruling that while affirmative defenses prevent judgment on pleadings, summary judgment is proper when no genuine factual issue exists. Substantively, the Court held Article 1267 applies only to obligations 'to do,' not 'to give' like rental payments. Economic difficulties do not excuse contractual performance absent absolutely exceptional circumstances. The decision reinforced contractual sanctity while clarifying proper procedural remedies, ultimately ordering payment of unpaid rentals and attorney's fees but deleting exemplary damages.