Case Digest (G.R. No. L-2342)
Facts:
Silverio Q. Cornejo v. Manuel B. Calupitan, D.B. Castaneda and Eustacio Barrera, G.R. No. L-2342, October 27, 1950, the Supreme Court En Banc, Montemayor, J., writing for the Court.Plaintiff-appellant Silverio Q. Cornejo offered in writing on January 4, 1945 to buy a 110.912‑hectare parcel in Barrio Mayabobo, Candelaria, Tayabas, from defendant‑owner Manuel B. Calupitan for P650,000, with P70,000 earnest money and the balance payable within fifteen days (Exhibit B), and Calupitan signed “Accepted by” on the same instrument. Calupitan had authorized real‑estate brokers D. B. Castaneda and Eustacio Barrera to handle the sale; they procured Cornejo’s offer and delivered it to Calupitan.
Cornejo could not immediately provide the P70,000 earnest money and on January 6, 1945 delivered only P65,000 in Japanese military notes through the brokers, together with a receipt (Exhibit C, carbon). The brokers gave a carbon copy to Calupitan, who instead wrote his own receipt (Exhibit M) acknowledging P65,000 “J. N.” (Japanese notes) as partial payment while specifying that the balance of P585,000 was to be paid “Philippine currency” on or before January 25, 1945. Cornejo did not pay the balance; claiming he sought Calupitan for delivery, he thereafter deposited P585,000 with the Clerk of Court and on January 22, 1945 filed suit for specific performance and damages against Calupitan and the brokers.
The Court of First Instance of Manila, through Judge Dionisio de Leon, absolved the defendants. The trial court found that Cornejo’s modification (reducing earnest money and extending time) abandoned the original agreement, that time was of the essence, and that Calupitan’s handwritten notation in Exhibit M manifested an intention that the balance be paid in genuine Philippine currency (not Japanese war notes); consequently there was no meeting of the minds and no perfected contract. The trial court nevertheless ordered that Calupitan return the value of the P65,000 Japanese notes to Cornejo.
Cornejo prosecuted a direct appeal to the Supreme Court from the Court of First Instance, expr...(Pro-only)
Issues:
- When a litigant brings a direct appeal from the Court of First Instance to the Supreme Court and limits the appeal to questions of law, may the Supreme Court disturb the trial court’s findings of fact?
- Did Exhibit M and the surrounding circumstances establish a meeting of the minds so that Calupitan accepted Cornejo’s modified offer and a binding contract for the sale of the land — specifically, did “Philippine currency” in Exhibit M mean Japanese military notes (as Cornejo contends) or genuine Philippine cu...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)