Marvin C. Amistoso v. First Leisure Ventures Group

Summary

Restaurant owner Marvin Amistoso claimed that First Leisure Ventures Group orally promised automatic lease renewal co-terminus with Vikings Restaurant operations when he agreed to relocate his establishment from one SM mall location to another. When the written lease contracts did not reflect these alleged oral agreements and SM Super Malls later refused to renew the lease, Amistoso filed for reformation of instrument and specific performance. The RTC dismissed the complaint for failure to state a cause of action, finding the written contracts clear and unambiguous. The Supreme Court reversed, ruling that the RTC erred by examining evidence beyond the complaint itself when determining sufficiency of allegations. The Court held that the complaint adequately alleged all elements of a cause of action, and that the veracity of the alleged oral promises was a matter for trial rather than dismissal. The case was remanded for further proceedings, establishing important precedent on the proper scope of inquiry when evaluating complaints for failure to state a cause of action.