Case Digest (G.R. No. 196795) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Corazon L. Escueta, et al. v. Rufina L. Lim (G.R. No. 137162, January 24, 2007), respondent Rufina L. Lim sued to remove a cloud on her title to ten lots purchase from petitioners Ignacio E. Rubio and the heirs of Luz R. Baloloy—Alejandrino and Bayani Baloloy—by virtue of a contract of sale dated April 10, 1990. She alleged payment of a P102,169.86 down payment to Rubio and P450,000 to the Baloloys, readiness to pay the balance upon presentation of titles, but refusal of petitioners to deliver such titles. She further claimed that petitioner Corazon L. Escueta, having knowledge of Lim’s purchase, obtained a simulated deed of sale from Rubio, thus clouding her title. The Baloloys were declared in default for failing to appear at pre‐trial, and the trial court in 1993 rendered partial judgment ordering them to execute deeds of sale in Lim’s favor or have the clerk do so, and awarded damages. Rubio and Escueta, after trial on the merits, obtained dismissal of Lim’s complaint in Case Digest (G.R. No. 196795) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Claim
- Respondent Rufina Lim filed a complaint for removal of cloud on title (quieting of title), specific performance, damages, injunction and hold-departure order against Ignacio E. Rubio; later amended to include heirs of Luz R. Baloloy (Alejandrino and Bayani) and Corazon L. Escueta.
- Allegations: respondent bought hereditary shares (10 lots) from Rubio and the Baloloys under contract dated April 10, 1990; paid down payments (₱102,169.86 to Rubio; ₱450,000 to Baloloys); vendors to deliver Torrens titles upon full payment; vendors refused to deliver titles or accept balance; Escueta held a “simulated” sale from Rubio, clouding title.
- Pleadings and Trial Court Proceedings
- Petitioners’ answers denied sale, claimed failure of respondent to pay balance and lack of authority of respondent’s alleged agents.
- Baloloys defaulted for failure to appear at pre-trial; trial court rendered partial decision (1993) ordering them to execute deeds of sale or clerk to do so and awarding damages and attorney’s fees. Their petition for relief denied (1994).
- On merits between respondent, Rubio and Escueta, trial court (1993) dismissed complaint against Rubio and Escueta, but ordered Rubio to return ₱102,169.80 with interest.
- Court of Appeals affirmed partial decision, reversed trial court’s dismissal, upheld respondent’s contract, voided sale to Escueta, ordered execution of deed by Rubio, and awarded respondent moral damages (₱20,000) and attorney’s fees (₱20,000).
- Supreme Court Appeal
- Petitioners sought certiorari to annul CA Decision (October 26, 1998) and Resolution (January 11, 1999).
- Petition raised: validity of Baloloys’ petition for relief; validity and binding effect of contract(s) of sale; authority of agent; nature of contract (sale vs. contract to sell); respondent’s compliance; validity of sale to Escueta; dismissal of petitioners’ counterclaims.
Issues:
- Whether the CA erred in denying the Baloloys’ petition for relief from judgment.
- Whether the CA erred in reinstating respondent’s complaint and awarding moral damages and attorney’s fees, considering:
- Rubio’s non-liability under contract between Virginia Laygo-Lim and respondent.
- Characterization of the contract as contract to sell, not sale.
- Respondent’s alleged non-compliance justifying cancellation.
- Escueta’s good faith in her sale.
- Whether the sale between Rubio and Escueta is valid.
- Whether the CA erred in dismissing petitioners’ counterclaims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)