Case Digest (G.R. No. 118248)
Facts:
In DKC Holdings Corporation v. Court of Appeals, Victor U. Bartolome and Register of Deeds for Metro Manila, District III, decided on April 5, 2000 under the 1987 Constitution, the 14,021–square–meter lot in Malinta, Valenzuela originally stood under Transfer Certificate of Title No. B-37615 in the name of Encarnacion Bartolome. On March 16, 1988, petitioner DKC Holdings Corporation entered into a Contract of Lease with Option to Buy granting it a two-year option to lease or purchase the property upon payment of a P3,000 monthly reservation fee and formal written notice. Encarnacion died in January 1990, whereupon her sole heir, private respondent Victor U. Bartolome, executed a self-adjudication, secured a new title (No. V-14249) and refused to accept further reservation or rental payments. On March 14, 1990, petitioner served notice of option to lease and tendered P15,000 rent; respondent declined both possession and payment. Petitioner then deposited the fees in a bank accounCase Digest (G.R. No. 118248)
Facts:
- Parties and Contract
- DKC Holdings Corporation (petitioner) entered on March 16, 1988 into a Contract of Lease with Option to Buy with Encarnacion Bartolome for a 14,021 sqm lot in Malinta, Valenzuela.
- Terms: reservation fee of ₱3,000/month for two years; option exercisable by written notice within two years; lease for six years at ₱15,000/month (renewable for another six years at ₱18,000/month) upon exercise.
- Succession and Title Transfer
- Encarnacion died January 1990; petitioner continued paying reservation fees to Victor U. Bartolome (sole heir), who refused them.
- Victor executed an Affidavit of Self-Adjudication; Register of Deeds cancelled TCT No. B-37615 and issued TCT No. V-14249 in Victor’s name.
- Exercise of Option and Registry Refusal
- March 14, 1990: petitioner served notice of exercise of option to lease and tendered ₱15,000 rent; Victor refused payment and possession.
- Petitioner deposited rents and reservation fees into a bank account in Victor’s name and attempted to register/annotate the contract; Register of Deeds refused to annotate.
- Lower Court Proceedings
- April 23, 1990: petitioner filed a complaint for specific performance and damages (Civil Case No. 3337-V-90).
- May 1990: Andres Lanozo moved to intervene as alleged tenant-tiller; intervention denied. Case referred to Agrarian branch and then to Branch 172.
- January 4, 1993: RTC dismissed the complaint, ordered petitioner to pay Victor ₱30,000 attorney’s fees.
- December 5, 1994: Court of Appeals affirmed the RTC decision in toto.
Issues:
- Whether the lease-with-option contract terminated upon Encarnacion’s death or binds her heir Victor under Article 1311, Civil Code.
- Whether petitioner complied with its contractual obligations and requisites for exercising the option.
- Whether the alleged tenancy of Andres Lanozo affected the validity or enforceability of the contract.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)