Case Digest (G.R. No. L-14714)
Case Digest (G.R. No. L-14714)
Facts:
Ariston Andaya, et al. v. Dr. Melencio Manansala, G.R. No. L-14714, April 30, 1960, the Supreme Court En Banc, Reyes, J., writing for the Court.Plaintiffs-appellees (spouses Ariston Andaya and Micaela Cabrito, joined by co-purchasers Ciriaco Casino and Fidela Valdez in earlier transactions) trace title to land originally sold by Isidro Fenis to Eustaquia Llanes on June 13, 1934, with a five-year right of repurchase. After that period expired without repurchase, Fenis sold the property to Maria Viloria on January 13, 1944. On August 21, 1944, Viloria sold the parcel to defendant-appellant Dr. Melencio Manansala by a sale with a one-year right to repurchase; on August 1, 1946 Manansala registered an affidavit consolidating title under the applicable law (Article 1509, Spanish Civil Code).
On September 28, 1947, Viloria executed an absolute sale of the same land to Ciriaco Casino, Fidela Valdez, and the plaintiffs for P4,800; thereafter, on October 18, 1947, Eustaquia Llanes sued (Civil Case No. 399) to quiet title and recover possession. On June 9, 1949, Manansala executed an absolute sale of the property to Casino, Valdez and the plaintiffs for P1,500 which contained a warranty against eviction; that conveyance was recorded in the Register of Deeds (the decree recitals in the record reflect these successive transfers and recordings).
Llanes’ action resulted in judgment in her favor; the decision became final on October 17, 1955, and execution followed, the plaintiffs being evicted. On March 23, 1956 the spouses Andaya filed suit in the Court of First Instance of Ilocos Sur against Manansala to recover damages, alleging breach of the warranty against eviction in the June 9 sale. The defendant denied liability, asserting that the buyers had solicited the sale to allow registration of their prior deed and that the warranty in the deed was understood by the parties to be pro forma.
After submission on agreed facts, the trial court held that the parties had waived the warranty as pro forma and that rescission remedies should apply; it ordered Manansala to return one-half the purchase price (P750) with interest and costs. Manansala appealed; because the questions raised were purely legal, the Court of Appeals forwarded the appeal to the Supreme Court for decision.
Issues:
- Did the Court of First Instance err in holding appellant liable on the theory of rescission and ordering return of the purchase price despite finding he was not liable for breach of warranty against eviction?
- Is appellant liable for damages under the warranty against eviction when the vendee waived the warranty and purchased with knowledge of the danger of eviction?
- May appellees recover additional damages under Article 1555 of the New Civil Code where the prior action that led to their eviction resulted in a final judgment from which they did not appeal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)