Sunday, April 14, 2019

Singson v Caltex (Phils.)

G.R. No. 137798 October 4, 2000
Art. 1250 – Extraordinary inflation or deflation

Facts:
·          Singson and Caltex entered into a contract of lease over a parcel of land in Quezon City to be used by respondent as a gasoline service station.
·          The contract of lease provides that the lease shall run for a period of 20 years, and that the monthly rental was fixed at P3,500.00 for the first 10 years, and at P4,200.00 for the succeeding 10 years of the lease.
·          Five years before the expiration of the lease contract, Singson asked Caltex to adjust or increase the amount of rentals citing that the country was experiencing extraordinary inflation.
·          Respondent refused on the basis of the clear provisions of rental fees.
·          Petitioner instituted a complaint to adjust rentals, invoked Article 1250 of the Civil Code, since the contract of lease was executed during extraordinary inflation.
·          The RTC, as affirmed by the CA, dismissed the complaint for lack of merit.

Issue:
WoN there existed an extraordinary inflation when the executed the contract that would call for the application of Article 1250 of the Civil Code and justify an adjustment or increase of the rentals between the parties.

Held:
            No, the Court holds that Article 1250 of the Civil Code is inapplicable in the instant case because such economic inflation during that period did not contemplate of a normal or ordinary decline in the purchasing power of the peso, and there was no even an official declaration thereof by competent authorities.
            It decrees that extraordinary inflation to exist when there is a decrease or increase in the purchasing power of the Philippine currency which is unusual or beyond the common fluctuation in the value of said currency, and such increase or decrease could not have been reasonably foreseen or was manifestly beyond the contemplation of the parties at the time of the establishment of the obligation.
            Thus, the petition is DENIED.

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