Title
Carabeo vs. Spouses Dingco
Case
G.R. No. 190823
Decision Date
Apr 4, 2011
Petitioner sold land rights to respondents but refused full payment; respondents sued for specific performance. SC upheld contract validity, ruling action survived petitioner's death.
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Case Digest (G.R. No. 190823)

Facts:

  1. Contract Execution: On July 10, 1990, Domingo Carabeo (petitioner) entered into a contract titled "Kasunduan sa Bilihan ng Karapatan sa Lupa" with Spouses Norberto and Susan Dingco (respondents). The contract involved the sale of petitioner's rights over a 648-square-meter unregistered land in Purok III, Tugatog, Orani, Bataan, for P38,000.
  2. Initial Payment: Respondents paid P10,000 upon signing the contract, with the remaining balance of P28,000 due in September 1990.
  3. Dispute Over Payment: Respondents claimed that petitioner refused to accept the balance due to an ongoing "squabble" over the land. They later gave petitioner small sums totaling P9,100. Petitioner, however, alleged that respondents failed to pay the full balance, forcing him to accept partial payments.
  4. Land Registration: In 1994, respondents discovered that the land dispute had been resolved, and petitioner had registered the land in his name on December 21, 1993, under Transfer Certificate of Title No. 161806.
  5. Offer to Pay Balance: Respondents offered to pay the remaining balance, but petitioner refused, prompting respondents to file a complaint for specific performance before the Regional Trial Court (RTC) of Balanga, Bataan.
  6. Petitioner's Defense: Petitioner argued that the sale was void for lack of a determinate object (no metes and bounds specified) and that respondents' failure to pay the balance rendered the action premature.
  7. Death of Petitioner: Petitioner died on January 31, 2001, before the RTC rendered its decision. His counsel failed to inform the court of his death or effect proper substitution under Section 16, Rule 3 of the Rules of Court.
  8. RTC Decision: On February 25, 2001, the RTC ruled in favor of respondents, ordering petitioner to execute a deed of sale upon payment of the remaining P18,900.
  9. Appeal: Petitioner's counsel filed a Notice of Appeal on March 20, 2001. The Court of Appeals affirmed the RTC decision on July 20, 2009.

Issue:

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Ruling:

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Ratio:

  1. Determinate Object in Contracts: A sale is valid if the object is capable of being made determinate without further agreement between the parties. The kasunduan sufficiently identified the land, satisfying this requirement.
  2. Judicial Consignation: While judicial consignation is a remedy for refusal to accept payment, the Court considered the respondents' lack of legal knowledge and the circumstances of the case.
  3. Spousal Consent: Issues raised for the first time on appeal are generally not entertained to ensure fairness and due process.
  4. Survival of Action: Actions involving property rights survive the death of a party. The trial court's judgment remained enforceable against petitioner's successors-in-interest.
  5. Effect of Death on Counsel's Authority: The death of a client immediately divests counsel of authority. Petitioner's counsel had no authority to file a Notice of Appeal, rendering the RTC decision final and executory.


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