Case Digest (G.R. No. 174660)
Facts:
On March 8, 1987, at Quezon City, Norma A. Rosel and her husband, Spouses Rodito F. Rosel (collectively, “respondents”), entered into a loan agreement with Natalia P. Bustamante and her late husband, Ismael C. Bustamante (collectively, “petitioner”), evidenced by TCT No. 80667 covering a 423‐sqm parcel along Congressional Avenue. Respondents borrowed ₱100,000.00 for two years at 18% interest per annum, pledging a 70‐sqm portion (with an existing apartment) as collateral. The contract granted respondents the option to purchase the collateral for ₱200,000.00 (inclusive of loan and interest) upon default by petitioner. When maturity fell on March 1, 1989, respondents insisted on exercising the option while petitioner tendered full payment and offered an alternative lot. Respondents refused both, insisting instead on a Deed of Sale. On February 28, 1990, respondents sued for specific performance with consignation, and, in turn, petitioner filed a petition for consignation, depositinCase Digest (G.R. No. 174660)
Facts:
- Loan agreement and collateral
- On March 8, 1987, Norma A. Rosel (borrower) and Natalia P. Bustamante with her late husband Ismael C. Bustamante (lenders) executed a loan agreement in Quezon City.
- Terms: principal of ₱100,000; 18% annual interest; two‐year maturity (from March 1, 1987 to March 1, 1989); collateral was a 70 m² portion of TCT No. 80667 with an embedded apartment. If borrowers failed to pay, lenders had the option to purchase that collateral for ₱200,000 (inclusive of principal and interest).
- Default, tender and consignation
- On March 1, 1989 (maturity), respondents offered to buy the collateral at ₱200,000; petitioner refused, tendered full payment, and proposed an alternative lot as down payment. Respondents rejected both.
- On March 5, 1990, petitioner filed a petition for consignation and deposited ₱153,000 with the Quezon City Treasurer. Respondents then consigned an additional ₱47,500 with the RTC representing unpaid interest.
- Judicial proceedings
- On February 28, 1990, respondents sued for specific performance with consignation before RTC, Quezon City (Branch 84).
- RTC decision (Nov. 10, 1992): denied execution of deed of sale; ordered payment of ₱100,000 plus 18% interest from March 2, 1989 to August 10, 1990; awarded ₱5,000 attorney’s fees.
- Court of Appeals (CA) decision (July 8, 1996): reversed RTC; ordered petitioner to execute sale deed over the 70 m² collateral upon respondents’ acceptance of ₱47,000 deposit and return to petitioner of her ₱153,000 deposit.
- Supreme Court proceedings: initial denial of petition (Feb. 9, 1998); petitioner’s motion for reconsideration; opposition by respondents; granted motion (April 21, 1998); final resolution (Nov. 29, 1999) granting the petition, reversing CA, and dismissing respondents’ complaint.
Issues:
- Whether petitioner failed to pay the loan at its March 1, 1989 maturity date.
- Whether the stipulation granting respondents an option to purchase the collateral at a fixed price of ₱200,000 constitutes a valid and enforceable agreement or an unlawful pactum commissorium.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)