Case Digest (G.R. No. 222482)
Facts:
In Faustino Cruz v. J.M. Tuason & Co., Inc., and Gregorio Araneta, Inc. (G.R. No. L-23749, April 29, 1977), plaintiff-appellant Faustino Cruz sued defendants-appellees J.M. Tuason & Co., Inc., and Gregorio Araneta, Inc., to recover the value of improvements he made on appellees’ land and to compel transfer of 3,000 square meters as agreed. In 1948, Cruz entered into an arrangement with the Deudors to clear and improve some 20 quinones of land (part of a 50-quinones tract covered by an “informacion posesoria”), spending ₱30,400 for labor and ₱7,781.74 for expenses. In 1952, appellees engaged Cruz as intermediary to negotiate a compromise in Civil Case No. Q-135 between themselves and the Deudors. Cruz alleged that appellees promised to convey him 3,000 sqm of the improved land “within ten years” after the compromise agreement of March 16, 1953 (approved April 11, 1953) as consideration for his services and that he fully performed. On January 24, 1964, he filed Civil Case No.Case Digest (G.R. No. 222482)
Facts:
- Nature of the Action and Parties
- Appellant Faustino Cruz sued defendants-appellees J. M. Tuason & Company, Inc. and Gregorio Araneta, Inc.
- Complaint filed January 24, 1964 in the Court of First Instance of Quezon City (Civil Case No. Q-7751).
- Alleged Causes of Action
- Unjust Enrichment/Quasi-Contract – Upon request of the Deudors, appellant made permanent improvements on 20 quinones of land (valued at P30,400.00) and incurred expenses (P7,781.74); appellees are alleged to benefit from those improvements.
- Contract to Convey 3,000 sq m – In 1952, appellees engaged appellant as intermediary in settling Civil Case No. Q-135 for 50 quinones of land; in consideration, appellees promised to convey to him 3,000 sq m within ten years from the court-approved compromise (March 16, 1953); appellees refused to convey.
- Proceedings Below
- Defendants’ Motions to Dismiss (Jan. 31 & Feb. 11, 1964) – Grounds: (a) no cause of action as improvements contract was with Deudors; (b) alleged conveyance agreement unenforceable under the Statute of Frauds; (c) action to compel conveyance prescribed.
- Appellant’s Oppositions and Trial Court Order (Aug. 13, 1964) – The court dismissed the complaint on all three grounds.
- Post-Judgment and Appeal
- Motion for Reconsideration (Aug. 20, 1964) denied September 7, 1964 as repetitive.
- Notice of Appeal filed September 24, 1964 (42 days after the August 13 order).
Issues:
- Does the complaint state a cause of action for reimbursement of improvements under Article 2142 (quasi-contract)?
- Is the alleged promise to convey 3,000 sq m enforceable or barred by the Statute of Frauds (Art. 1403, Civil Code)?
- Has the action to compel conveyance prescribed under the applicable prescription period?
- Did the motion for reconsideration toll the 30-day period to appeal, rendering the appeal timely?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)