Case Digest (G.R. No. 47501)
Facts:
The case involves Felix B. Bautista and Melquiades B. Bautista (the "recurrentes") as petitioners against Gabriel Lasam (now deceased), Rosa Carbonel, and others (the "recurridos"). The events leading to the case began with a sale of land where Gabriel Lasam, the seller, sought payment from the Bautista brothers for an alleged unpaid balance of P8,000, which was the remaining price for a property measuring 2,130 hectares located in Solana, Cagayan. The payment was claimed to be due in two installments of P2,000 and P6,000, which were supposed to be paid in May 1930 and May 1932, respectively, along with 12% annual interest and an additional 25% for attorney's fees.
The Court of First Instance of Cagayan ruled in favor of Lasam, ordering the Bautista brothers to pay P7,257 instead of the claimed amount, plus interest and attorney's fees. Dissatisfied with this ruling, the Bautista brothers appealed to the Court of Appeals, arguing several points ...
Case Digest (G.R. No. 47501)
Facts:
Parties Involved:
- Recurrentes (Appellants): Felix B. Bautista and Melquiades B. Bautista, brothers and practicing lawyers.
- Recurridos (Appellees): Gabriel Lasam (now deceased), Rosa Carbonel, and others.
Subject Matter:
- The case involves a dispute over the payment of the balance of the purchase price for a land transaction. Gabriel Lasam (the seller) sued Felix and Melquiades Bautista (the buyers) for the unpaid balance of P8,000, plus interest and attorney’s fees, related to the sale of a 2,130-hectare land in Solana, Cagayan.
Key Allegations:
- The buyers claimed that the land sold was only 1,445 hectares, not 2,130 hectares, and sought a reduction in the purchase price.
- They also argued that the seller failed to deliver the title for 671 hectares, which they could not register under their names.
- The buyers further contended that the trial court erred in ordering them to pay P7,257 with 12% annual interest and 10% attorney’s fees.
Trial Court Decision:
- The Court of First Instance of Cagayan ruled in favor of the seller, ordering the buyers to pay P7,257 with 12% interest from June 2, 1930, and 10% attorney’s fees.
Appeal to the Court of Appeals:
- The buyers appealed, raising four errors:
- The trial court erred in not declaring the land sold as only 1,445 hectares.
- The trial court erred in not deducting the value of the 671 hectares not registered.
- The trial court erred in ordering payment of P7,257 with interest and attorney’s fees.
- The trial court erred in not absolving the buyers and ordering the seller to pay damages.
- The Court of Appeals affirmed the trial court’s decision.
- The buyers appealed, raising four errors:
Evidence Presented:
- The deed of sale (Exhibit A) was drafted by Felix B. Bautista and finalized by Melquiades B. Bautista.
- The deed mentioned that the land was registered under the Spanish system and that the parties agreed to register it under the Unregistered Lands Act if necessary.
- The buyers took possession of the land but failed to register 671 hectares.
Buyers’ Letters to the Seller:
- The buyers acknowledged their obligation to pay the seller in several letters sent between 1931 and 1935, without mentioning any breach by the seller.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Eviction and Warranty of Title:
- Under Article 1475 of the Civil Code, eviction occurs when the buyer is deprived of the property due to a prior right. For eviction to apply, the following must concur:
- A final judgment depriving the buyer of the property.
- The deprivation must be based on a right existing before the sale.
- The seller must be notified of the eviction claim.
- In this case, the buyers were not deprived of the land, and the seller was not notified of any eviction claim. Thus, the seller is not liable for eviction.
- Under Article 1475 of the Civil Code, eviction occurs when the buyer is deprived of the property due to a prior right. For eviction to apply, the following must concur:
Reduction of Purchase Price:
- The buyers argued that the land area was less than stated in the contract. However, the Court found that the sale was made at a lump sum price, and the buyers took possession of the land without protest.
- Under Article 1471 of the Civil Code, when a sale is made at a lump sum price, there is no increase or decrease in price based on the actual area, unless the contract specifies otherwise.
Buyers’ Obligation to Pay:
- The buyers acknowledged their obligation to pay in several letters to the seller, without raising any issues about the seller’s breach. This acknowledgment negates their claim for damages or reduction in price.
Attorney’s Fees and Costs:
- The trial court and the Court of Appeals correctly awarded attorney’s fees and costs to the seller, as the buyers’ claims lacked merit.