Case Digest (G.R. No. 135382)
Facts:
In Jocelyn B. Doles v. Ma. Aura Tina Angeles, respondent Angeles filed on April 1, 1997 before the Regional Trial Court (RTC) of Manila a complaint for Specific Performance with Damages against petitioner Doles. Angeles alleged that Doles owed her a personal loan of ₱405,430.00 and executed on October 5, 1996 a Deed of Absolute Sale conveying a 42-sqm lot in Camella Townhomes Sorrente, Bacoor, Cavite (TCT No. 382532), to satisfy the debt. The property was encumbered by a NHMFC mortgage of ₱337,050.00, which Angeles agreed to assume, including arrears of ₱26,744.09. Doles allegedly refused to pay arrears, obstructed the transfer, and collected rent for January 1997 without remitting proceeds. Doles denied indebtedness, claiming she merely referred friends to Angeles’s financier, Arsenio Pua, and was threatened into signing the deed under fear of criminal prosecution for Batas Pambansa Blg. 22 violations. The RTC dismissed Angeles’s case on July 29, 1998 for lack of cause and quesCase Digest (G.R. No. 135382)
Facts:
- Nature and origin of the dispute
- On April 1, 1997, respondent Ma. Aura Tina Angeles filed in RTC Manila (Civil Case No. 97-82716) a Complaint for Specific Performance with Damages against petitioner Jocelyn B. Doles.
- Respondent alleged:
- Petitioner owed her a personal loan of ₱405,430.00 (principal and interest).
- On October 5, 1996, by a “Deed of Absolute Sale,” petitioner sold a 42 sqm parcel (TCT No. 382532, Camella Townhomes Sorrento, Bacoor, Cavite) to respondent to satisfy that debt.
- The property was mortgaged to NHMFC for ₱337,050.00, and respondent agreed to assume the remaining mortgage balance and pay ₱4,748.11 monthly for the unexpired 25-year term.
- Petitioner allegedly incurred ₱26,744.09 arrears on the NHMFC amortization, refused to pay or execute transfer documents, and wrongfully withheld January 1997 rent (₱3,000).
- Petitioner’s defense
- Petitioner admitted referring friends to respondent (financier: Arsenio Pua) for loans in mid-1995; she acted as intermediary.
- The friends issued post-dated checks which bounced; petitioner attempted to help collect but the borrowers disappeared.
- Respondent threatened criminal prosecution (BP Blg. 22) and forced petitioner to issue eight checks (₱350,000) and to execute the Deed of Absolute Sale without valid consideration, not before a notary, and with a falsified CTC number.
- Petitioner claimed damages and lost rental income.
- Procedural history
- RTC Branch 21 (July 29, 1998) dismissed the complaint for insufficiency of evidence, holding the sale void for lack of cause and noting co-ownership issues on the title.
- CA (April 30, 2001) reversed, ruling petitioner was the true borrower, the sale had valid consideration (₱405,430.00), and ordering petitioner to execute transfer documents (arrearages to be borne by respondent).
- CA denied petitioner’s motion for reconsideration (Aug 6, 2001).
- Petitioner filed a Rule 45 Petition (Aug 28, 2001), raising:
- Whether petitioner was respondent’s debtor.
- Whether an unauthorized agent may collect debt directly.
- Whether the sale had a valid cause.
Issues:
- Whether petitioner can be considered the debtor of respondent.
- Whether an agent not authorized by the principal to collect debt may directly collect payment.
- Whether the Deed of Absolute Sale was executed for a valid cause or consideration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)