FACTS:

The case involves a dispute between respondent United Philippine Scout Veterans Detective and Protective Agency (United), a security agency, and petitioner Nissan North Edsa (Nissan), a corporation engaged in the car dealership business. United and Nissan entered into a contract for security services, whereby United provided 18 security guards to be posted in Nissan's compound. However, due to alleged violations of the contract's provisions, Nissan informed United that its services would be terminated. United pleaded for reconsideration, but when Nissan failed to act on the request, United demanded payment for 30 days of service in accordance with the contract's requirement of a 30-day prior written notice for termination. As Nissan did not comply with United's demand, the latter filed a case for sum of money with damages before the Metropolitan Trial Court. The trial court ruled in favor of United, ordering Nissan to pay actual damages, exemplary damages, attorney's fees, and other litigation expenses. Nissan appealed to the Regional Trial Court, which affirmed the decision of the Metropolitan Trial Court. Nissan's appeal to the Court of Appeals was also denied, with the modification of deleting the award for exemplary damages. Nissan filed a petition for review before the Supreme Court, asserting that United failed to present the service contract as evidence during the trial. The Supreme Court dismissed Nissan's petition, ruling in favor of United. The court held that the best evidence rule did not apply because the contents of the service contract were not in dispute. The real issue in the case was whether Nissan had committed a breach of contract, which the court found in the affirmative based on Nissan's failure to substantiate its claim that United violated the contract's provisions. The court affirmed the decisions of the lower courts, ordering Nissan to pay the damages awarded to United.

ISSUES:

1. Whether or not the failure of the respondent's security guards to report for duty constitutes a violation of the service contract, justifying the termination without prior notice.

RULING:

1. The Court held that the failure of the respondent's security guards to report for duty does not constitute a violation of the service contract that would justify termination without prior notice. The petitioner failed to provide evidence to substantiate its claim of violations committed by the respondent. Therefore, the act of unilaterally terminating the contract constitutes a breach of contract, entitling the respondent to collect actual damages.

PRINCIPLES:

• The best evidence rule applies only when the contents of a document are the subject of the inquiry.

• To terminate a contract without prior notice, there must be clear violations of its provisions.