Case Digest (G.R. No. 138639)
Facts:
City-Lite Realty Corporation v. Court of Appeals and F.P. Holdings & Realty Corp., G.R. No. 138639, February 10, 2000, Supreme Court Second Division, Bellosillo, J., writing for the Court.The dispute arose over a 71,754-sq.m. parcel (the “Violago Property”) owned by F. P. Holdings and Realty Corporation (formerly Sparta Holdings, Inc.), which offered the property for sale through a public sales brochure that identified Meldin Al G. Roy of Metro Drug, Inc. as the contact person. The brochure described the property, the asking price of P6,250.00/sq.m., and contact particulars; the front portion of 9,192 sq.m. became the subject of negotiations with City-Lite Realty Corporation (City‑Lite).
On 25 September 1991 Roy (on behalf of Metro Drug) transmitted a written counteroffer setting price and payment terms (P15 million downpayment; balance payable within six months). On 26 September 1991 City‑Lite, through its officers and counsel, accepted those terms in writing. When F.P. Holdings refused to execute a deed of sale, City‑Lite caused an adverse claim to be annotated on the title (27 September 1991) and demanded conveyance. F.P. Holdings then filed a petition to cancel the adverse claim in the Regional Trial Court (RTC), Quezon City (LRC Case No. 91‑10257, raffled to Br. 84).
The RTC (Br. 84) dismissed F.P. Holdings' petition on 2 December 1991, finding City‑Lite's adverse claim not sham. City‑Lite thereafter filed a complaint for specific performance and damages; during the suit the property was re‑surveyed and a new TCT issued, later transferred to Viewmaster Construction Corp., prompting amendment of the complaint to implead Viewmaster and the Register of Deeds (case raffled to RTC Br. 85). On 4 October 1995 RTC‑Br. 85 ruled for City‑Lite, ordering F.P. Holdings to execute the deed of sale for a total consideration of P55,056,250.00 and directing cancellation of the title issued to Viewmaster.
Viewmaster moved for reconsideration (arguing, inter alia, lack of definite payment terms), which was denied. The Court of Appeals (Seventh Division) on 20 October 1998 reversed the RTC, concluding no perfected contract of sale existed and that Roy/Metro Drug lacked authority to sell. The CA d...(Pro-only)
Issues:
- Was a valid, perfected contract of sale formed between City‑Lite and F.P. Holdings (through Metro Drug/Meldin Al G. Roy)?
- Did Metro Drug/Meldin Al G. Roy have authority to sell the Violago Property on behalf of F.P...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)