Case Digest (G.R. No. 255038) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ricardo Cheng vs. Ramon B. Genato and Ernesto R. Da Jose & Socorro B. Da Jose, decided on December 29, 1998 under G.R. No. 129760, respondent Ramon B. Genato owned two parcels at Paradise Farms, San Jose del Monte, Bulacan (TCT Nos. T-76.196 (M) and T-76.197 (M)). On September 6, 1989, Genato executed a public Contract to Sell with the Da Jose spouses at ₱80/m², with a ₱50,000 down payment and ₱950,000 due 30 days later upon title verification. The Da Jose spouses secured an annotation on the titles. They obtained a 30-day extension to verify the titles, which Genato later claimed was conditional on executing a new contract within seven days—a claim the Da Jose spouses denied. Without notifying them, Genato executed an Affidavit to Annul Contract to Sell on October 13, 1989, but only annotated it on October 26, 1989, after petitioner Cheng reminded him. On October 24, 1989, Cheng, aware of the Da Jose spouses’ prior contract, paid Genato ₱50,000 and obtained a handwritten rec Case Digest (G.R. No. 255038) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract Between Genato and Da Jose Spouses
- On September 6, 1989, Ramon B. Genato (Vendor) executed a Contract to Sell with Ernesto R. Da Jose and Socorro B. Da Jose (Vendees) over two lots in Paradise Farms, Bulacan (TCT Nos. T-76.196 (M) and T-76.197 (M)), at ₱80/m², annotated on the titles the same day.
- Clause 1 provided a down payment of ₱50,000; Clause 3 required payment of the remaining ₱950,000 within 30 days after satisfactory title verification, upon which possession would be delivered.
- Extension, Affidavit of Annulment, and Sale to Cheng
- On October 4, 1989, the Da Jose spouses obtained a 30-day extension (to November 5) to verify titles; Genato later claimed a new condition (new documents in 7 days), which the spouses denied.
- Without notice, Genato executed an Affidavit to Annul the Contract to Sell on October 13, 1989 (breach alleged for non-payment by October 6), but only annotated it on October 26, 1989 after reminder by Cheng.
- On October 24, 1989, Ricardo Cheng expressed interest, inspected the titles and the annulment affidavit, then issued a check for ₱50,000; Genato gave a handwritten receipt (Exh. D) and later deposited the check but sought to return it after deciding to honor the Da Jose spouses’ contract.
- Payments, Intervention, and Court Proceedings
- The Da Jose spouses, upon learning of the affidavit on October 27, 1989, reiterated willingness to pay; on November 2 they paid the ₱950,000 and issued three post-dated checks for the balance (encashment stayed by litigation).
- On December 8, 1989, Cheng sued for specific performance to compel sale to him; Genato answered the check was an option deposit, not earnest money, and conditioned on annulment of the prior contract. The Da Jose spouses intervened as first vendees.
- RTC (Jan. 18, 1994) held the Da Jose contract rescinded by affidavit, ordered sale to Cheng, and awarded nominal damages and attorney’s fees. CA (July 7, 1997) reversed, ruling the prior contract was not validly rescinded, the sale to Cheng unenforceable, Da Jose spouses had priority, and Cheng acted in bad faith; awarded damages.
Issues:
- Whether the Contract to Sell between Genato and the Da Jose spouses was validly rescinded by the Affidavit to Annul.
- Whether the agreement between Genato and Cheng constituted a perfected Contract to Sell or a conditional contract of sale enforceable against prior rights.
- Whether Cheng is liable for damages due to bad faith and wrongful interference with Genato’s contractual relations with the Da Jose spouses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)