Case Digest (G.R. No. L-21957)
Facts:
Lauro Adamos et al. v. J. M. Tuason & Co., Inc., G.R. No. L-21957. October 14, 1968, the Supreme Court En Banc, Makalintal, J., writing for the Court.The plaintiffs (thirty-three individuals) sued J. M. Tuason & Co., Inc. and Gregorio Araneta, Inc. (as managing partner and attorney-in-fact) in the Court of First Instance of Manila, pleading causes of action for specific performance and damages. They alleged they had purchased residential lots in Matalahib and Tatalon, Quezon City in 1949 from several vendors collectively referred to as the “Deudors,” that those lots formed part of a larger parcel covered by a Torrens title in the name of J. M. Tuason & Co., Inc., and that the purchasers were included in a March 16, 1953 compromise agreement (embodied in a court decision) under which the purchasers were to be credited prior payments and the defendant corporation was to execute new purchase contracts at prevailing rates.
The complaint alleged that plaintiffs were willing to sign and pay under the new contracts but that defendants refused to execute them despite verbal and written demands; their third and fourth causes of action concerned the proper price under the compromise and claimed damages and attorney’s fees. The prayer sought an order compelling defendants to execute new purchase contracts at the rates then current (P17–P20 per square meter) and recovery of damages.
Defendants filed motions to dismiss claiming (variously) improper venue, failure to state a cause of action, extinctive prescription, and misjoinder. The Court of First Instance of Manila dismissed the complaint for failure to state a cause of action, relying on extraneous proceedings in the Court of First Instance of Rizal that had led to orders (dated February 28, 1957 and January 10, 1958) and subsequent Supreme Court decisions (including Florencio Deudor et al. v. J. M. Tuason & Co., Inc., G.R. No. L-13768, May 30, 1961, and J. M. Tuason & Co., Inc., et al. v. Bienvenido Sanvictores, G.R. No. L-16886, Jan. 30, 1962) which, according to the lower court, had effectively rescinded or set aside the compromise agreement insofar as it remained unimplemented.
Plaintiffs’ motion for reconsideration was de...(Pro-only)
Issues:
- Did the Court of First Instance err in dismissing the complaint for failure to state a cause of action by taking cognizance of extraneous facts (the alleged rescission of the compromise agreement)?
- Was venue improperly laid such that the action should have been filed in the Court of First Instance of the Province of Rizal wher...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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