Case Digest (G.R. No. 143781)
Facts:
- On April 8, 1994, Jose Clavano, Inc. (Petitioner) entered into a contract to sell a house and lot in Cebu City to spouses Enrique and Venus Tenazas (Respondents).
- The Tenazas paid 50% of the purchase price but struggled to pay the remaining balance and additional charges.
- Claiming default by the Tenazas, Jose Clavano, Inc. refused further payments and filed a lawsuit for rescission of the contract and forfeiture of payments.
- The lawsuit was dismissed, and the petitioner did not pursue further action.
- The Tenazas then filed a complaint for specific performance with the Housing and Land Use Regulatory Board (HLURB), seeking to compel the petitioner to honor the contract.
- On November 14, 1995, the HLURB ruled in favor of the Tenazas, ordering the petitioner to accept payment, execute a Deed of Absolute Sale, and deliver the Transfer Certificate of Title, along with damages and attorney's fees.
- The Office of the President upheld the HLURB's decision on March 12, 1998, but deleted the award for moral damages.
- The petitioner’s attempts to challenge the HLURB's decision were dismissed by the Court of Appeals and the Supreme Court.
- On August 31, 1999, the HLURB decision became final and executory, leading to a writ of execution.
- The petitioner was compelled to surrender documents related to the sale.
- On March 23, 1999, the Tenazas filed a motion with the HLURB regarding defects in the housing unit and an unnotarized deed of sale.
- The HLURB ordered the petitioner to pay for notarization and transfer fees, which the petitioner contested.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioner, Jose Clavano, Inc.
- The Court set aside the HLURB's orders requiring the petitioner to pay for notarization and transfer expenses, stating these obligations were not part of the...(Unlock)
Ratio:
- The Supreme Court emphasized the principle of finality of judgments, stating that once a decision is final and executory, it cannot be amended or modified except for clerical errors.
- The HLURB's subsequent orders to require the petitioner to pay for notarization and title transfer expenses ...continue reading
Case Digest (G.R. No. 143781)
Facts:
On April 8, 1994, Jose Clavano, Inc. (Petitioner) entered into a contract to sell a house and lot located in Cebu City to spouses Enrique and Venus Tenazas (Respondents). The Tenazas paid 50% of the purchase price but faced difficulties in settling the remaining balance and additional charges. Claiming default on the part of the Tenazas, Jose Clavano, Inc. refused to accept further payments and subsequently filed a lawsuit for rescission of the contract and forfeiture of the payments made. This suit was dismissed, and the petitioner did not pursue further action. In response, the Tenazas filed a complaint for specific performance with the Housing and Land Use Regulatory Board (HLURB) in Cebu City, seeking to compel the petitioner to honor the contract. They alleged that they had tendered sufficient payment, which the petitioner unreasonably refused to accept. On November 14, 1995, the HLURB ruled in favor of the Tenazas, ordering the petitioner to accept the payment, execute a Deed of Absolute Sale, and deliver the corresponding Transfer Certificate of Title, along with damages and attorney's fees. The HLURB's decision was upheld by the Office of the President on March 12, 1998, although the award for moral damages was deleted. The petitioner’s subsequent attempts to challenge the HLURB's decision were dismissed by the Court of Appeals and later by the Supreme Court. On August 31, 1999, the HLURB decision became final and executory, leading to the issuance of a writ of execution. The petitioner was compell...