Case Digest (G.R. No. 151821)
Facts:
Bank of the Philippine Islands, as successor-in-interest of BPI Investment Corporation v. ALS Management & Development Corp., G.R. No. 151821, April 14, 2004, First Division, Panganiban, J., writing for the Court.Petitioner Bank of the Philippine Islands (BPI) (successor-in-interest of BPI Investment Corporation) sued respondent ALS Management & Development Corporation on July 29, 1985 in the Regional Trial Court (RTC) for the reimbursement of P26,300.45 allegedly advanced by petitioner for issuance and registration of a Condominium Certificate of Title to Unit E-4A of the Twin Towers Condominium (Deed of Sale dated July 22, 1983). The Deed of Sale provided that the vendee (respondent) would pay expenses for registration and issuance of the title; petitioner paid the expenses but respondent allegedly refused reimbursement despite demands.
Respondent filed an Answer with Compulsory Counterclaim alleging breach of warranties and defective/delayed delivery of the condominium unit, relying on features and representations in petitioner's sales brochure and claiming (among others) non‑installation of a closed-circuit TV monitor, various construction defects, and late delivery (contract professed completion by Dec. 31, 1981; actual delivery June 1982). Respondent claimed corrective specific performance and damages: reimbursement of completion expenses (P40,000), unearned rental/lease income in U.S. dollars for certain periods, monthly losses after lessee vacated, attorneys’ fees, costs, and litigation expenses.
On February 6, 1990, the RTC rendered judgment: it ordered respondent to pay petitioner P26,300.45 plus legal interest; ordered petitioner to deliver, replace or correct specified defects (with detailed listings by room/area); and ordered petitioner to pay respondent P40,000 (reimbursement), P136,608.75 (unearned income for a five‑month suspension), and P27,321.75 per month for twenty‑one months (alleged unearned income when unit remained vacant), with legal interest.
The Court of Appeals (Tenth Division, penned by Justice Ramon A. Barcelona) affirmed the RTC in a Decision dated November 24, 2000; its January 9, 2002 Resolution deni...(Subscriber-Only)
Issues:
- Was the trial court without jurisdiction to entertain respondent’s counterclaims because jurisdiction belonged exclusively to the HLURB (formerly NHA/HSRC)?
- Are the factual findings of the RTC and CA — particularly on breach of brochure warranties, existence of defects, and responsibility to correct — supported by evidence or are they clearly erroneous?
- Were the damage awards (reimbursement of completion work, awards for unearned lease income and suspension losses) adequately ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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