Case Digest (G.R. No. 115838) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Constante Amor de Castro and Corazon Amor de Castro, co-owners of four lots at EDSA corner New York and Denver Streets in Cubao, Quezon City, executed a handwritten letter dated January 24, 1984, authorizing Francisco Artigo as their real estate broker at a 5% commission on an asking price of P23,000,000.00. Artigo introduced Times Transit Corporation, which ultimately purchased two of the lots (lots 14 and 15) in May–June 1985 for an alleged P7,050,000.00. The De Castros paid Artigo P48,893.76 in partial commission, after which Artigo demanded the remaining P303,606.24. On May 29, 1989, he sued the De Castros in Civil Case No. Q-89-2631 before the Regional Trial Court of Quezon City, Branch 80, for unpaid commission, moral damages, and attorney’s fees. On December 20, 1991, the trial court held the De Castros jointly and solidarily liable for P303,606.24 representing unpaid commissions, P25,000.00 as moral damages, P45,000.00 as attorney’s fees, and costs. On May 4, 1994, the C Case Digest (G.R. No. 115838) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Constante and Corazon Amor de Castro were co-owners of four lots at EDSA corner New York & Denver Streets, Cubao, Quezon City.
- Respondent Francisco Artigo, a real estate broker, was authorized to sell these properties.
- Agency Contract and Sale
- On January 24, 1984, Constante (representing all co-owners) executed a handwritten letter authorizing Artigo to sell the properties for ₱23,000,000 at a 5% commission, “first-come, first-serve.”
- Artigo introduced Times Transit Corporation, which agreed to buy two lots (lots 14 and 15). In May 1985 the sale was consummated, and Artigo received an advance commission of ₱48,893.76.
- Litigation History
- Artigo claimed total commission of ₱352,500 (5% of ₱7,050,000) and sued on May 29, 1989 for the balance of ₱303,606.24.
- The Regional Trial Court (Branch 80, Quezon City) on December 20, 1991 ordered Constante and Corazon jointly and solidarily liable for the balance, plus ₱25,000 moral damages, ₱45,000 attorney’s fees, and costs.
- The Court of Appeals, in CA-G.R. CV No. 37996, affirmed the trial court decision on May 4, 1994. Petitioners filed this Rule 45 petition for certiorari.
Issues:
- Should the complaint be dismissed for failure to implead indispensable co-owners?
- Was Artigo’s claim extinguished by full payment, waiver, or abandonment?
- Did the courts err in admitting incompetent evidence to determine the selling price?
- Did the courts improperly credit perjured testimony?
- Was the award of moral damages and attorney’s fees unwarranted?
- Should the De Castros have been awarded moral/exemplary damages and attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)