Title
Bautista vs. Maxino
Case
G.R. No. L-21935
Decision Date
Feb 22, 1978
Property sold twice; buyer sues for unpaid debt. Maxino spouses' claims for damages denied due to waiver, lack of evidence, and buyer's ownership rights. Supreme Court affirms trial court ruling.
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Case Digest (G.R. No. L-21935)

Facts:

Background of the Sale
On March 19, 1956, defendant spouses Jose Ma. Maxino and Loreto Capinpin de Maxino sold their hacienda, fishponds, and agricultural equipment located in San Jose, Occidental Mindoro, to plaintiff Pilar T. Bautista for P70,000.00. The sale included the condition that Bautista would assume the payment of a mortgage obligation with the Rehabilitation Finance Corporation (RFC), now the Development Bank of the Philippines, amounting to P181,652.34.

Subsequent Sale to San Jose Development Company
On May 17, 1958, Pilar T. Bautista sold the same property to the San Jose Development Company, represented by Francisco G. Guballa, for P80,000.00. The payment was structured as P20,000.00 upon execution and the balance in three annual installments of P20,000.00 each.

Conflicting Sale to Guballa Spouses
On August 7, 1958, the Maxino spouses also sold the same property to the Guballa spouses for P80,000.00.

Outstanding Debt and Legal Action
As of May 17, 1961, Francisco G. Guballa had an outstanding obligation of P30,000.00 to Pilar T. Bautista, which he failed to pay despite demands. This led Bautista to file a complaint for collection of the debt, damages, and costs of suit. The Maxino spouses were impleaded as defendants for allegedly conspiring to defraud Bautista through the execution of a deed of sale to the Guballa spouses.

Trial Court Decision
The trial court dismissed Bautista's claims for damages but ordered the Guballa spouses to pay P30,000.00 with legal interest. The Maxino spouses' counterclaim for damages was also dismissed, prompting their appeal.

Issue:

  1. Whether the Maxino spouses are entitled to damages for the alleged failure of Bautista to pay an additional purchase price of P80,000.00 and assumed obligations with FILASIDECO.
  2. Whether the Maxino spouses are entitled to reimbursement for expenses incurred to prevent foreclosure by the RFC.
  3. Whether the Maxino spouses are entitled to reimbursement for payments made to hacienda workers.
  4. Whether the Maxino spouses are entitled to the value of fruits gathered by Bautista from the property.
  5. Whether the Maxino spouses are entitled to moral damages and attorney’s fees for the allegedly malicious filing of the complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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