Case Digest (G.R. No. 196359) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In FELIX CHINGKOE AND ROSITA CHINGKOE vs. FAUSTINO CHINGKOE AND GLORIA CHINGKOE (G.R. No. 244076, March 16, 2022), petitioners Felix and Rosita Chingkoe sought specific performance against respondents Faustino and Gloria Chingkoe over a parcel of land in Lopez Jaena Street, Ayala Heights, Quezon City (TCT No. 8283). Faustino and Gloria were the registered owners, but Felix had occupied the property since 1989 with Faustino’s consent. At the behest of their mother, Tan Po Chu, Faustino signed an undated Deed of Sale in Felix’s favor—allegedly to pacify his alcoholic brother. On October 10, 1994, Felix and Faustino executed a notarized Deed of Absolute Sale before Atty. Reynaldo Z. Calabio for ₱3,130,000.00. Although Felix repeatedly demanded the Owner’s Duplicate of TCT No. 8283, respondents refused and even mortgaged the land to RCBC. In June 1995, Felix filed a complaint for specific performance with damages. The RTC, in its May 12, 2014 Decision (later modified on July 30, 201 Case Digest (G.R. No. 196359) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Faustino and Gloria Chingkoe (defendants) are registered owners of a parcel covered by TCT No. 8283 in Quezon City.
- Felix and Rosita Chingkoe (plaintiffs) claim that Felix occupied the property since 1989 and purchased it in 1994 for ₱3,130,000.00.
- Alleged Deed of Sale and Possession
- In 1990, Faustino signed an undated Deed of Sale at the behest of their mother, Tan Po Chu, purportedly to appease Felix.
- On October 10, 1994, Felix and Faustino signed a notarized Deed of Absolute Sale before Atty. Calabio; Faustino then refused to surrender the owner’s duplicate title.
- Felix discovered Faustino had mortgaged the property to RCBC, prompting a suit for specific performance and damages.
- Procedural History
- RTC Branch 101, Quezon City (May 12, 2014): Declared due execution of the Deed of Sale, awarded attorney’s fees, and later ordered surrender of the duplicate title.
- CA (April 30, 2018): Reversed RTC, giving weight to Tan Po Chu’s testimony and finding lack of consideration for the sale.
- This Supreme Court petition under Rule 45 challenges the CA decision.
Issues:
- Whether the Court of Appeals correctly overturned the presumption of regularity of the notarized Deed of Sale based on Tan Po Chu’s testimony.
- Whether Felix sufficiently proved payment of the ₱3,130,000.00 purchase price to satisfy the consideration requirement.
- Whether Felix is entitled to actual damages for lost business opportunity due to non‐surrender of the title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)