G.R. No. 122544 - Dizon vs. Court of Appeals

Petitioners: Regina P. Dizon, Amparo D. Bartolome, Fidelina D. Balza, Ester Abad Dizon, and Joseph Anthony Dizon; Raymund A. Dizon, Gerard A. Dizon, and Jose A. Dizon, Jr.
Respondents: Court of Appeals and Overland Express Lines, Inc., with private respondent being a key party in the factual matrix.
Initial trial court judgment was rendered on November 22, 1982 in Civil Case No. VIII-29155 of the then City Court (now Metropolitan Trial Court) of Quezon City, Branch III, later affirmed by higher courts.
The Supreme Court eventually revisited the matter on January 28, 1999, and subsequently on March 21, 2001 during oral arguments.

A sum of P300,000.00 was received on June 20, 1975 through Alice A. Dizon, who purported to act on behalf of petitioners.
The central factual dispute focuses on whether the receipt of the payment was intended as:

Another key issue is whether Alice Dizon possessed the proper authority, particularly in writing, to receive such payment on behalf of the petitioners.

Private respondent contended that the receipt of the P300,000.00 gave rise to a perfected contract of sale, thereby binding petitioners.
The issue of whether there existed a valid, perfected contract of sale or at least a contract of sale concerning the shares of Fidel and Alice Dizon was central to the dispute.
It is noted that the contract of lease between the parties had an option to purchase, which expired after one year, and the subsequent implied renewal of the lease on a monthly basis did not revive this option.

A Motion for Reconsideration;
A Second Motion for Reconsideration; and
A Motion to Suspend Procedural Rules in the Higher Interest of Substantial Justice.

These motions were denied by the Supreme Court.
The Court also directed the remand of the case records to the trial court for the execution of the prior judgment, with an order that petitioners refund the P300,000.00 received through Alice A. Dizon.

Whether there exist circumstances sufficient to justify the suspension of the Rules of Court, supported by strong compelling reasons such as serving the ends of justice and preventing a miscarriage thereof.

Whether Alice A. Dizon was authorized, through proper written powers or otherwise, to receive the money on behalf of petitioners.
If she was authorized:

Whether petitioners were thereby estopped from later questioning the belated exercise of private respondent’s option to buy; and
Whether Alice Dizon could validly bind petitioners in the absence of a written power of attorney.

Whether there was a perfected contract of sale between the petitioners and private respondent.
Alternately, whether there was at least a contract of sale with respect to the shares of Fidel and Alice Dizon.