Case Digest (G.R. No. 46530) Core Legal Reasoning Model
Facts:
In Ulysses Rudi V. Banico v. Lydia Bernadette M. Stager (G.R. No. 232825, September 16, 2020), petitioner Ulysses Rudi V. Banico contracted on February 8, 1992 with respondent Lydia Bernadette M. Stager (substituted by her compulsory heirs) for the Deed of Absolute Sale of an 800-square-meter portion of Lot No. 199 in Barangay Manoc-Manoc, Boracay Island, for P350,000.00. Although Banico intended to purchase the flat seaside terrain for a beach resort, the deed mistakenly described the elevated rocky northern part. Upon taking possession, surveying and commencing construction, Banico discovered the discrepancy. Stager orally undertook to correct the deed but instead persuaded Banico later that year to acquire an adjacent 400-square-meter lot for P160,000.00 on installment, which Banico partly paid. In 1997, Stager refused to execute an amended deed, alleging an unpaid balance. In 2001, before the barangay, she presented a notarized deed dated December 6, 2001, accurately descri
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Case Digest (G.R. No. 46530) Expanded Legal Reasoning Model
Facts:
- Antecedents
- Lydia Bernadette M. Stager owned a 6,100 sq m parcel (Lot 199) in Boracay. In February 1992, she and Ulysses Rudi Banico executed a Deed of Absolute Sale for an 800 sq m portion described as the northern, rocky part of Lot 199, with a beachfront of 40 m, for ₱350,000.00.
- Upon payment, Banico took possession of the flat terrain, surveyed it, and discovered the deed described the wrong portion. Stager agreed to correct the deed and persuaded Banico to buy an adjacent 400 sq m for ₱160,000.00 on installment, formalized October 19, 1992.
- Barangay Proceedings and Acknowledgment
- In 2001, Banico sought barangay mediation. Stager presented a notarized December 6, 2001 Deed of Absolute Sale covering the 800 sq m flat terrain with correct boundaries for ₱80,000 (admitted price discrepancy), but Banico refused signature.
- Stager did not dispute Banico’s occupation or construction on the flat terrain and accepted most payments for the 400 sq m lot, though a ₱12,000 balance remained in her view.
- Judicial Proceedings
- July 9, 2002: Banico filed for specific performance and reformation of the February 8, 1992 sale and damages (RTC Civil Case No. 02-104001). Stager died in 2012; heirs substituted.
- February 18, 2015: RTC ordered reformation of the February 8, 1992 deed to reflect the flat terrain and found a ₱6,600 balance on the 400 sq m lot; denied damages.
- February 22, 2017: Court of Appeals (CA) denied reformation as time-barred under the 10-year prescription for written contracts; reduced Banico’s balance to ₱5,860; denied damages.
- July 11, 2017: CA denied motions for reconsideration—Stager’s heirs arguing rescission for nonpayment and Banico arguing tolling by 2001 acknowledgment and full payment.
- Supreme Court Petition
Issues:
- Reformation and True Intention
- Whether the February 8, 1992 Deed of Absolute Sale may be reformed for mutual mistake in the technical description of the 800 sq m lot.
- Whether counsel’s drafting error precludes reformation when parties’ acts demonstrate a different intention.
- Prescription
- Whether the 10-year prescriptive period for actions on written contracts or reformation was tolled by Stager’s December 6, 2001 acknowledgment.
- Payment and Damages
- Whether Banico fully paid the ₱160,000 purchase price for the 400 sq m lot and what balance remains.
- Whether either party is entitled to damages for breach or error.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)