Case Digest (G.R. No. 212980) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of Buenavista Properties, Inc. and/or Josephine Conde vs. Ramon G. Mariao, G.R. No. 212980, the legal conflict stems from a Joint Venture Agreement (JVA) dated September 30, 1993, between the Spouses Buencamino and Spouses San Juan (the landowners) and La Savoie Development Corporation (La Savoie). Under this agreement, La Savoie was authorized to develop three parcels of land in San Rafael, Bulacan, into a commercial and residential subdivision known as the Buenavista Park Subdivision, and manage the sales of the lots. It was stated that the pricing of the lots would be determined jointly by La Savoie and the landowners. Subsequently, the landowners sold their interests to Josephine Conde, who later assigned these interests to Buenavista Properties, Inc. (BPI).
In compliance with the JVA, an addendum was executed that extended the period of development until 1997. However, as development progressed, BPI repeatedly requested La Savoie to halt the sale of the lots un
Case Digest (G.R. No. 212980) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transactional Background
- The primary parties include:
- The landowners, namely the Buencamino and San Juan spouses;
- La Savoie Development Corporation, the developer;
- Josephine Conde, from whom Buenavista Properties, Inc. (BPI) acquired rights; and
- Ramon G. MariAo, who contracted to purchase a lot in the subdivision.
- The parties initially entered into a Joint Venture Agreement (JVA) whereby La Savoie was empowered to develop three parcels of land in San Rafael, Bulacan into the Buenavista Park Subdivision and to manage sales and marketing.
- The pricing of the lots was to be determined by the joint agreement of the landowners and La Savoie.
- Developments and Subsequent Agreements
- After the JVA, the landowners sold their property rights to Josephine Conde who, in turn, assigned her interest to BPI.
- BPI and Conde executed an Addendum to the JVA extending the development period to 1997.
- Prior to significant development, BPI, through Conde, sent several letters to La Savoie requesting:
- A suspension of sales until the project had sufficient development to justify better pricing; and
- A mutual agreement on revised lot prices.
- Despite these requests, La Savoie continued with the sale of subdivision lots.
- Contract to Sell and Legal Proceedings
- On July 18, 1997, La Savoie and MariAo executed a Contract to Sell a subdivision lot.
- The contract stipulated that upon full payment, La Savoie would execute a final deed of sale in MariAo’s favor.
- On February 28, 1998, BPI filed a complaint before the Regional Trial Court (RTC) seeking:
- Termination of the JVA;
- Recovery of properties plus damages; and
- Issuance of a temporary restraining order and a writ of preliminary injunction.
- The RTC later:
- Issued a writ of preliminary injunction on August 11, 1998; and
- In a decision dated June 12, 2003, terminated the JVA and ordered La Savoie to deliver possession of the subdivision to BPI.
- Administrative and Appellate Proceedings
- MariAo initiated an action for specific performance before the Housing and Land Use Regulatory Board (HLURB), which:
- Ordered BPI to deliver the title covering the purchased lot to MariAo; and
- Imposed exemplary damages, attorneys’ fees, and costs.
- The Court of Appeals (CA) affirmed earlier decisions (including the RTC’s decision) and held that:
- La Savoie’s sale was not ultra vires;
- BPI was bound by the conduct of La Savoie pursuant to Article 1911 of the Civil Code; and
- The delivery of the title was obligatory since the Contract to Sell had been properly executed before any termination.
- Subsequent petitions and motions:
- BPI filed a petition for review on certiorari before the Supreme Court based on various arguments including the alleged limited authority of La Savoie and lack of privity in the Contract to Sell;
- The petition raised issues already settled by the HLURB, CA, and even the Office of the President (OP); and
- Multiple motions for reconsideration were subsequently filed by BPI, including one on November 10, 2014, and another on June 1, 2016.
- Extrajudicial Communications and Court Interventions
- Mr. Delfin V. Cruz, a party related to BPI, wrote several letters to the Court and its members (dated November 25, 2014; June 21, 2016; July 28, 2016; and September 3, 2016) expressing:
- His concerns over what he perceived as “railroading” of the case;
- His contention that La Savoie lacked authority to sell; and
- His appeal to the Court’s sense of fairness and “hiya”.
- The Court took note of these interventions and ultimately required clarification of Mr. Cruz’s relationship with BPI and whether he was duly authorized to communicate on its behalf.
- Final Court Actions and Resolutions
- The Supreme Court, on April 4, 2016, issued a minute resolution denying BPI’s first motion for reconsideration with finality.
- On June 1, 2016, BPI filed a second motion for reconsideration with leave of Court which was later noted as a prohibited second motion under the Rules of Court.
- The Court, in its detailed ruling, maintained that no further pleadings or motions would be entertained and warned against any future interference in the case.
Issues:
- Authority of Sale
- Whether La Savoie was empowered under the JVA and its Addendum to sell the subdivision lots, including the lot sold to MariAo.
- Whether BPI’s prior withdrawal of authority was effective or if it was still operative at the time of the contract with MariAo.
- Validity and Admissibility of Subsequent Motions
- Whether BPI’s second motion for reconsideration (filed on June 1, 2016) is permissible under Section 2, Rule 52 and Section 3, Rule 15 of the Rules of Court, given that a prior motion for reconsideration had already been disposed of.
- Whether the issues raised in the motions were merely repetitive of those already adjudicated by the HLURB, CA, and OP.
- Implications of Extrajudicial Communications
- Whether Mr. Delfin V. Cruz's letters, not being formally submitted by counsel, affect the proceedings, or if they constitute improper interference with the Court’s process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)