Tala Realty Services Corp. v.

Banco Filipino Savings and Mortgage Bank

G.R. No. 132051 June 25, 2001

FACTS:
Tala alleged that on the basis of a contract of lease executed on August 25, 1981. its contract with Banco Filipino expired on August 31, 1992. However, Banco
Filipino has continued to occupy the premises even after the expiration of the lease. On June 2, 1993, Tala imposed upon Banco Filipino the following terms and
conditions: that the bank should pay P70,050.00 as monthly rental retroactive as of September 1, 1992, with rental escalation of 10% per year; and advance
deposit equivalent to rents for four months, plus a goodwill of P500,000.00. Banco Filipino did not comply and in April 1994, it stopped paying rents. Banco Filipino
denied having executed the lease contract providing for a term of eleven (11) years; claiming that its contract with Tala is for twenty (20) years, citing the Contract
of Lease executed on August 25, 1981.

ISSUE:
Whether or not the eleven-year lease contract superseded the twenty-year lease contract

HELD:
The eleven (11)-year contract is a forgery because (1) Teodoro O. Arcenas, then Executive Vice-President of private respondent Banco Filipino, denied having
signed the contract; (2) the records of the notary public who notarized the said contract, Atty. Generoso S. Fulgencio, Jr., do not include the said document; and (3)
the said contract was never submitted to the Central Bank as required by the latter's rules and regulations. It is not the eleven (11)-year lease contract but the
twenty (20)-year lease contract which is the real and genuine contract between petitioner Tala Realty and private respondent Banco Filipino. Considering that the
twenty (20)-year lease contract is still subsisting and will expire in 2001 yet, Banco Filipino is entitled to the possession of the subject premises for as long as it
pays the agreed rental and does not violate the other terms and conditions thereof. The validity of the twenty (20) year lease contract was further reinforced on
June 20, 2000 when the First Division of this Court rendered a Decision in G.R. No. 137980, likewise upholding the twenty (20)-year lease contract, thus:

"In light of the foregoing recent Decision of this Court (G.R. No. 129887), we have no option but to uphold the twenty-year lease contract over the eleven-year
contract presented by petitioner. It is the better practice that when a court has laid down a principle of law as applicable to a certain state of facts, it will adhere to
that principle and apply it to all future cases where the facts are substantially the same. 'Stare decisis et non quieta movere.

That the principle of stare decisis applies in the instant case, even though the subject property is different, may be gleaned from the pronouncement in Negros
Navigation Co., Inc. vs. Court of Appeals. Stare decisis simply declares that, for the sake of certainty, a conclusion reached in one case should be applied to those
which follow, if the facts are substantially the same, even though the parties may be different. Considering the above rulings, the term of the lease in the present
case is also twenty (20) years.
TALA REALTY SERVICES CORP VS. BANCO FILIPINO SAVINGS
AND MORTGAGE BANK
GR 137980 JUNE 20, 2000
FACTS:
Respondent has a legal problem with regard to its real estate holdings.
The law requires that respondents real estate holdings should only be
50% of its net worth. This constituted a bar to the planned expansion
of respondent. To solve the predicament of the respondent, it created
a separate entity, which is petitioner, wherein the existing branch sites
would be unloaded and the said petitioner would also acquire new
branch sites for respondent and lease it to the latter. Pursuant to the
agreement between the two parties, the petitioner acquired properties
from respondent and then leased them to the latter. It was a part of
the agreement that petitioner only holds properties for the respondent
and that the said properties would be returned to respondent at its
pleasure.
There came a time when there was a disagreement between the two
parties on which of the 2 lease contracts of lease presented by each
party governs them. Petitioner contends that it is the 11-year contract
while the other presents a 20-year contract. Both contracts have been
allegedly notarized and executed on the same date.
Using the 11-year contract as basis, the petitioner filed a petition for
ejectment against respondent. However, the petitioner lost in all its
cases and appealed the case to the Court of Appeals. The CA
mentioned in its decision that the lower courts erred in refusing to
exercise jurisdiction, when the issue of possession and issue of validity
of contract is intertwined. Nonetheless, it dismissed the petition to
maintain judicial consistency and stability as other ejectment cases
like the one at bar have already been decided on. Petitioner filed MR
and was granted by ordering respondent to pay the unpaid rentals.
Subsequently, the respondent filed an MR and the CA reversed its
decision, which made petitioner file an appeal to the SC saying that
the CA erred in considering the ruling of the court in another case as
the law of the case between petitioner and respondent. Respondent then
said that only decisions of the SC establish jurisprudence or
doctrines.
ISSUE:
Whether or not the principle of stare decisis should be applied to
the case at bar even if the parties and properties involved are
different?
HELD:
The stare decisis principle should be upheld.
There had been previously a decision by the SC involving the
same parties but different property, wherein it was upheld and decided
that the 20-year lease contract should prevail. It even mentioned in
its decision that the 11-year contract was forged and simulated as it
was never really notarized nor submitted to the Central Bank, as
required by law.
In the light of the aforementioned decision, the Court doesnt
have any option but to uphold the 20-year lease contract, following the
principle of stare decisis et non quieta movere (follow past precedents
and do not disturb what has been settled).
It is the policy of the Court to maintain judicial stability in
accordance to stare decisis. As in this case, the same questions
relating to the same even have been put forward by parties similarly
situated as in a previous case litigated and decided by a competent
court, the rule of stare decisis is a bar to any attempt to relitigate the
same issue. The ruling is final even as to parties who are strangers to
the original proceedings and not bound by the judgment under the res
judicata doctrine. Stare decisis should apply if the facts are
substantially the same even if the parties may be different.