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KEY TAKE-AWAY OR DOCTRINE TO REMEMBER

Stare
quietamovere>
movere (To stand
decisions
and
notv.to
disturb
settled
matters)
<Staredecisis
decisis et
et non
non quieta
<Tala by
Realty
Services
Corp.
Banco
Filipino
Savings
and Mortgage Bank>
<Charry
Blue
Bacina>
Courts are bound by prior decisions. Thus, once a case has been decided one way, courts have no choice
<G.R.No. 132051> <June 25,2011> <Sandoval-Gutierrez. J>

but to resolve subsequent cases involving the same issue in the same manner
RECIT-READY / SUMMARY

TALA alleges that its 11 year lease contract with Banco Filipino has expired, Banco Filipino argues that it
has no violation as the contract it signed wa a 20 year lease contract. The courts cannot say that the 20
year lease contract is invalid as they did recognize its validity in past 2 cases. BF was still asked to
vacate premisese for reason of non payment of rentals.
FACTS
Because of limitations that Banco Filipino has, as a commercial bank, to purchase hold and convey real
estate, its stakeholders, hereafter TALA, agreed on Talas acquisition of the existing branch sites and
new branch sites which it would lease out to Banco Filipino.

1. TALA, years after, filed 3 cases on these grounds a) expiration of lease agreement and b) nonpayment of rentals.
Note: Branch of the case: Iloilo branch. | (version of TALA) Terms of lease: 11 years, renewable for
another 9 years | Lease date: Aug. 31, 1981

2. TALA imposed fines, Banco Filipino did not comply, TALA demanded payment and evacuation
Note: Banco Filipino stopped paying rentals by April 1994

3. Banco Filipino response: We did not violate any contract of lease.


Note: (version of Banco Filipino) Terms of lease: 20 years executed on Aug. 21, 1981

4. July 1, 1996, MTC decision: TALA is right with 11 years, BF ordered to pay
5. BF appealed, RTC: affirmed MTC. BF appealed again, CA: afirmed RTC
6. BF Supplemental Motion for Reconsideration: CA upheld the validity of the lease contract providing for a
period of twenty (20) years on the illegal detainer case filed by TALA in BF Malabon branch.
7. CA reversed decision of MTC and RTC and dismissed TALAs claim and version of terms of lease.
8. 11 years version: forged [EVP denied signature, Notary Public has no copy, Central Bank no copy]
ISSUES / RATIO
1. WON the eleven-year lease contract

ARTICLES/LAWS INVOLVED

superseded the twenty-year lease contract

Stare decisis et non quieta movere (To stand by decisions


and not to disturb settled matters)

HELD
NO. The 11 year lease contract does not apply as it is proven to be a forged contract. Moreover and
more importantly:
"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.
Note: Banco Filipino was still asked to evacuate premises for reason of non-payment of rentals

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