Case Digest (G.R. No. 103577)
Facts:
Romulo A. Coronel, Alarico A. Coronel, Annette A. Coronel, Annabelle C. Gonzales (for herself and on behalf of Floraida C. Tupper, as attorney-in-fact), Cielito A. Coronel, Floraida A. Almonte, and Catalina Balais Mabanag, Petitioners, vs. The Court of Appeals, Concepcion D. Alcaraz and Ramona Patricia Alcaraz, assisted by Gloria F. Noel as attorney-in-fact, Respondents, G.R. No. 103577, October 07, 1996, Supreme Court Third Division, Melo, J., writing for the Court.In January 1985 the Coronel heirs (hereafter petitioners/Coronels) executed a document entitled “Receipt of Down Payment” reflecting a P1,240,000.00 transaction for a house and lot (originally under TCT No. 119627). The document recited receipt of a P50,000 down payment from Ramona Patricia Alcaraz (through her mother, Concepcion D. Alcaraz, who actually tendered the check) and recited that the Coronels would effect a transfer of title into their names and, upon presentation of the title, execute a deed of absolute sale after which Ramona would pay the P1,190,000 balance.
On February 6, 1985 a new title in the Coronels’ names (TCT No. 327043) was issued. On February 18, 1985 the Coronels sold the same property to Catalina B. Mabanag for P1,580,000 (with a P300,000 payment). The Coronels deposited the original down payment in trust and, after notice events, Catalina caused annotation of an adverse claim and later obtained a new title in her name (Deed dated April 25, 1985; new TCT issued June 5, 1985). Concepcion (on behalf of Ramona) filed suit for specific performance on February 22, 1985 and annotated a lis pendens.
The case was submitted to the Regional Trial Court (Branch 83, Quezon City) on documentary evidence and, on March 1, 1989, Judge Reynaldo Roura (then on detail) granted specific performance in favor of Concepcion and Ramona, ordered cancellation of Catalina’s title and delivery of possession to plaintiffs, and dismissed other claims. A motion for reconsideration seeking annulment and decision by the incumbent presiding judge was denied by the new presiding judge on July 12, 1989. The Court of Appeals affirmed on December 16...(Subscriber-Only)
Issues:
- Was the document entitled “Receipt of Down Payment” a perfected contract of sale or merely a contract to sell/conditional contract?
- If it was a conditional sale, was the suspensive condition fulfilled and, if so, did the parties’ reciprocal obligations become demandable?
- Did the subsequent sale to Catalina B. Mabanag and her later registration defeat Ramona’s prior rights — i.e., was Catalina a good-faith registrant entitled to prevai...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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