In MANILA INTERNATIONAL AIRPORT AUTHORITY, Petitioner, vs. DING VELAYO SPORTS CENTER, INC., Respondent, G.R. No. 161718, December 14, 2011, the Supreme Court held that the petitioner could not oppose the renewal of the lease because of estoppel. It must be noted, however, that in MIAA, supra, the Supreme Court held, inter alia, that “there is no estoppel when the statement or action invoked as its basis did not mislead the adverse party”. Estoppel has been characterized as harsh or odious, and not favored in law. “Estoppel cannot be sustained by mere argument or doubtful inference”. It must be “clearly proved in all its essential elements by clear, convincing and satisfactory evidence.” No party should be precluded from making out his case according to its truth unless by force of some positive principle of law, and, consequently, estoppel in pais must be applied strictly and should not be enforced unless substantiated in every particular.
The Supreme Court held therein that the essential elements of estoppel in pais may be considered in relation to the party sought to be estopped, and in relation to the party invoking the estoppel in his favor. As related to the party to be estopped, the essential elements are: (1) conduct amounting to false representation or concealment of material facts; or at least calculated to convey the impression that the facts are otherwise than, and inconsistent with, those which the party subsequently attempts to assert; (2) intent, or at least expectation that his conduct shall be acted upon by, or at least influence, the other party; and (3) knowledge, actual or constructive, of the real facts.
