G.R. No. 207500 - EFREN S. QUESADA, PETER CHUA, ARTURO B. PEREJAS, ERLINDA ESCOTA, CRISANTO H. LIM, VASQUEZ BUILDING SYSTEMS CORPORATION, LION GRANITE CONSTRUCTION SUPPLY CORPORATION, NELLIE M. MARIVELES, ALEJANDRO V. VARDELEON III, ANGELITA P. ROQUE, DAVID LU, J.A.O. BUILDERS & DEVELOPMENT CORPORAT

Ruling

Accordingly, Bonanza had no basis to unilaterally terminate the lease without offending the mutuality of contracts. The period o{the lease had not yet expired. There is also no merit in Bonanza's contention that the contract which was " effective July 1, 2003 and until such time that it is replaced or amended by another resolution " had expired because the Board of Directors had already issued a board resolution terminating the lease. Bonanza interprets the term "resolution" to mean a board resolution from Bonanza. This erroneous interpretation is offensive to the mutuality and obligatory force of contracts. The contract actually states: Effectivity - This agreement shall be effective July 1, 2003 and until such time that it is replaced or amended by another resolution agreement . [52] We point out that Bonanza has conveniently omitted the word "agreement" whenever it cited the effectivity of the contract. This omission is misleading and unethical. A lease contract is onerous in character containing reciprocal obligations; any ambiguities in its terms are interpreted in favor of the greatest reciprocity of interests . [53] Accordingly, "resolution" or "resolution agreement" should be interpreted to mean a subsequent agreement between the lessor and the lessee instead of a unilateral resolution from the lessor's board of directors. There was no ground for summary ejectment. A summary proceeding for unlawful detainer contemplates a situation where the defendant's possession, while initially lawful, had legally expired. Under the Civil Code, a lessor may judicially eject the lessee for any of the following causes: Article 1673. The lessor may judicially eject the lessee for any of the following causes: (1) When the period agreed upon , or that which is fixed for the duration of leases under articles 1682 and 1687, has expired ; (2) Lack of payment of the price stipulated; (3) Violation of any of the conditions agreed upon in the contract; (4) When the lessee devotes the thing leased to any use or service not stipulated which causes the deterioration thereof; or if he does not observe the requirement in No. 2 of article 1657, as regards the use thereof. The ejectment of tenants of agricultural lands is governed by special laws. [54] The presence of any of these circumstances authorizes the lessor to directly resort to the MTC/MeTC for summary ejectment. The lessor is no longer required to file a separate complaint for rescission before the RTC. [55] However, none of these circumstances is present in this case. First , the contract did not specifically fix the period of the obligation. Therefore, we cannot conclude that the lease had already expired. While the nature and the circumstances of the contract make it apparent that a period was intended, this does not authorize the lessor to unilaterally conclude that the period had lapsed or to summarily eject the lessee. The Civil Code only grants the lessor the right to ask the courts to fix the period.