Title
Source: Supreme Court
Communities Cagayan, Inc. vs. Spouses ol
Case
G.R. No. 176791
Decision Date
Nov 14, 2012
Spouses entered a Contract to Sell, defaulted on payments, and built a new house. SC ruled partial reimbursement under Maceda Law and Article 448, remanding for valuation of improvements and property.

Case Digest (G.R. No. 176791)
Expanded Legal Reasoning Model

Facts:

  • Parties and Initial Transactions
    • Petitioner Communities Cagayan, Inc. (formerly Masterplan Properties, Inc.) and respondents Spouses Arsenio (deceased) and Angeles Nanol entered into a Contract to Sell in 1994 involving a house and Lots 17 and 19, Block 16, Camella Homes Subdivision, Cagayan de Oro City, for ₱368,000.
    • Respondents secured a loan from Capitol Development Bank by executing a simulated sale; titles were transferred to their names (TCT Nos. 105202, 105203) but the bank collapsed before releasing funds.
  • Second Contract, Improvements, Default
    • On November 30, 1997, the parties executed another Contract to Sell for the same property and price, this time availing of petitioner’s in-house financing over four years (1997–2001).
    • In 2000, Arsenio demolished the original house and built a three-story structure valued at approximately ₱3.5 million. Arsenio died in July 2001; Angeles continued the amortizations.
  • Notices and Litigation
    • On September 10, 2003, petitioner issued a notarized Notice of Delinquency and Cancellation for failure to pay installments. An unlawful detainer suit filed in December 2003 was dismissed due to respondents’ registered titles.
    • On July 27, 2005, petitioner filed before the RTC, Cagayan de Oro City, Branch 18 (Civil Case No. 2005-158), a Complaint for Cancellation of Title, Recovery of Possession, Reconveyance, and Damages.
    • The parties agreed to submit on pleadings and exhibits. On December 29, 2006, the RTC declared the Deed of Absolute Sale void for lack of consideration, cancelled TCT Nos. 105202 and 105203, and ordered respondents to vacate subject to payment of all monthly installments and the value of the new house minus the original house cost. Reconsideration was denied on February 12, 2007.

Issues:

  • Whether the RTC erred in ordering petitioner to reimburse respondents the total monthly installments paid.
  • Whether the RTC erred in ordering reimbursement of the value of the new house minus the cost of the original house.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.