The Supreme Court ruled that a lessor’s failure to ensure the peaceful and adequate enjoyment of a leased property by the lessee constitutes a breach of contract, justifying rescission. This means lessors must actively address issues that disrupt a lessee’s business operations, such as unresolved utility bills or delayed construction, or risk having the lease agreement rescinded and being liable for damages. This decision reinforces the importance of fulfilling contractual obligations in lease agreements.

When Billboard Construction Disrupts Business: Upholding a Lessee’s Right to Peaceful Enjoyment

This case revolves around a lease agreement between Spouses Socrates and Cely Sy (lessors) and Andok’s Litson Corporation (lessee). Andok’s sought to rescind the contract due to alleged breaches by the Sys. These breaches included an unpaid MERALCO bill and delays caused by the construction of a billboard by another tenant, MediaPool, Inc., on the leased property. The central legal question is whether the Sys’ actions constituted a breach of their obligation to provide Andok’s with peaceful and adequate enjoyment of the leased premises, thereby justifying the rescission of the lease agreement.

The Regional Trial Court (RTC) ruled in favor of Andok’s, a decision affirmed by the Court of Appeals. The Supreme Court upheld these rulings, emphasizing the lessor’s responsibility to ensure the lessee’s undisturbed use of the property. The Court cited Article 1191 of the Civil Code, which provides for the power to rescind obligations in reciprocal contracts when one party fails to comply with their duties. A lease contract, being reciprocal, requires the lessor to grant possession of the property in exchange for rental payments.

Article 1659 of the Civil Code specifically addresses lease contracts, stating:

Art. 1659. If the lessor or the lessee should not comply with the obligations set forth in articles 1654 and 1657, the aggrieved party may ask for the rescission of the contract and indemnification for damages, or only the latter, allowing the contract to remain in force.

Articles 1654 and 1657 outline the obligations of the lessor and lessee, respectively. Pertinently, Article 1654 states the lessor is obliged:

Article 1654. The lessor is obliged:

(1) To deliver the thing which is the object of the contract in such a conditions as to render it fit for the use intended;

(2) To make on the same during the lease all the necessary repairs in order to keep it suitable for the use to which it has been devoted, unless there is a stipulation to the contrary;

(3) To maintain the lessee in the peaceful and adequate enjoyment of the lease for the entire duration of the contract.

The Supreme Court found that the Sys failed to fulfill their obligation under Article 1654(3). While Andok’s complied with its obligations as a lessee, the Sys did not ensure the premises were fit for Andok’s intended use nor maintain their peaceful enjoyment of the property. The Court underscored that this obligation requires the lessor to prevent interruptions or disturbances to the lessee’s enjoyment, whether caused by the lessor’s actions or the actions of others.

The Sys argued that Andok’s assumed the risk of delay by allowing MediaPool, Inc. to construct a billboard on the property. However, the Court rejected this argument, pointing to the conditional nature of Andok’s agreement. Paragraph 10 of the contract stipulated that construction required approval from both Andok’s and the Sys to avoid disruption. The Court noted that the Sys were aware that the billboard construction could disrupt Andok’s operations. Despite Andok’s repeated demands to expedite the construction, the Sys remained indifferent, thus violating their obligation.

The Court also addressed the legal interest imposed on the monetary award. Citing Eastern Shipping Lines, Inc. v. Court of Appeals, the Court affirmed the imposition of a 6% per annum legal interest from the date of the trial court’s judgment (24 July 2008) until its finality. Upon finality, the interest rate would increase to 12% per annum until the judgment is fully satisfied.

FAQs

What was the key issue in this case?	The key issue was whether the lessors breached their obligation to ensure the lessee’s peaceful and adequate enjoyment of the leased premises, justifying rescission of the lease agreement. The breaches included unresolved utility bills and delays in billboard construction.
What is a lessor’s primary obligation in a lease agreement?	A lessor’s primary obligation is to deliver the property in a condition suitable for its intended use and to maintain the lessee’s peaceful and adequate enjoyment of the property throughout the lease term. This includes addressing issues that may disrupt the lessee’s business operations.
Under what circumstances can a lease agreement be rescinded?	A lease agreement can be rescinded if either the lessor or lessee fails to comply with their obligations, as outlined in Articles 1654 and 1657 of the Civil Code. This typically involves a substantial breach that significantly impairs the other party’s ability to benefit from the contract.
What is the effect of a valid motion to reset a pre-trial conference?	A valid motion to reset a pre-trial conference, supported by sufficient evidence and a legitimate reason, should be granted by the court. However, the court has the discretion to deny such motions if the reason is unsubstantiated or frivolous.
What happens if a party fails to appear at a pre-trial conference?	If the plaintiff fails to appear, their action may be dismissed. If the defendant fails to appear, the plaintiff may be allowed to present evidence ex-parte, and the court may render judgment based on that evidence.
What damages can be awarded in a rescission case?	In a rescission case, the aggrieved party may be entitled to recover advance rentals and deposits, as well as damages for losses incurred due to the breach. This may include costs associated with preparing the premises for business operations.
What is the legal interest rate applicable to monetary awards?	The legal interest rate is 6% per annum from the date of judgment until its finality. Once the judgment becomes final and executory, the interest rate increases to 12% per annum until the judgment is fully satisfied.
What should a lessor do if a lessee complains about disturbances?	A lessor should promptly investigate and address any complaints from the lessee regarding disturbances to their peaceful enjoyment of the property. This may involve communicating with other tenants, resolving utility issues, or taking other necessary actions to rectify the situation.

This case underscores the critical importance of lessors fulfilling their obligations to ensure lessees can peacefully and adequately enjoy the leased property. Failure to do so can lead to rescission of the lease agreement and liability for damages. Lessors must actively address issues that disrupt the lessee’s business, demonstrating a commitment to upholding the terms of the lease.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Spouses Socrates Sy and Cely Sy vs. Andok’s Litson Corporation, G.R. No. 192108, November 21, 2012