Case Digest (G.R. No. L-3645)
Facts:
J. Antonio Araneta, como Administrador de la Testamentaria de la Finada Angela S. Tuason v. Rural Progress Administration, G.R. No. L-3645, October 08, 1952, the Supreme Court En Banc, Pablo, M., writing for the Court.The dispute arose from correspondence beginning November 5, 1947, when the Rural Progress Administration (RPA) through its administrator offered to consider extra-judicial purchase of a Sta. Mesa estate owned by the late Angela S. Tuason and asked whether she would agree to sell rather than await expropriation. On April 28, 1948 the RPA informed Araneta (administrator of the testamentary estate) that its Board had decided to acquire a portion of the lands at P7.00 per square meter and, if that price were agreeable, it would negotiate a loan with the Rehabilitation Finance Corporation (RFC) to cover the purchase price.
Araneta, acting as testamentary administrator, replied that he would recommend sale to the probate court but stated explicit conditions: the area not to exceed seven hectares; exclusion of parcels under lease until 1953; segregation of the seven hectares; relocation of tenants/squatters to the segregated portion; retention of rights to collect arrears; and an understanding that acceptance of the sale would preclude further petitions by tenants against Lot 19C. Subsequent correspondence in May 1948 concerned a subdivision sketch the RPA needed for its RFC loan application; Araneta returned the sketch with the segregated area traced in blue.
By November 11, 1948 Araneta pressed the RPA for a definitive answer because tenants were withholding rent pending Government purchase. The RPA reiterated its April 15, 1948 board approval and disclosed that it had applied for a P500,000 RFC loan to pay for the seven hectares but that the RFC then lacked funds; it expected funding once the Central Bank opened. On March 22, 1949 Araneta served an ultimatum demanding payment by month-end or suit for specific performance.
Araneta sued the RPA in the Court of First Instance of Manila seeking specific performance. After trial the court ordered the RPA to pay P490,000 (the value of seven hectares at P7 per square meter), plus 6% interest from April 27, 1949, and required Araneta to execute a deed of sale upon payment. The RPA appealed the judgment to the Supreme Court.
...(Subscriber-Only)Issues:
- Was there a perfected, enforceable contract of sale between the testamentary administrator and the Rural Progress Administration obligating the RPA to pay P7.00 per square meter for seven hectares?
- If no perfected contract existed, was the RPA in default (mora) and liable to specific p...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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