Case Digest (G.R. No. 205810) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Estate of Valeriano C. Bueno and Genoveva I. Bueno, represented by Valeriano I. Bueno, Jr. and Susan I. Bueno (Petitioners) versus Estate of Atty. Eduardo M. Peralta, Sr. and Luz B. Peralta, represented by Dr. Edgardo B. Peralta (Respondents), the dispute concerns a Transfer Certificate of Title No. 47603 covering a house and lot at 3450 Magistrado Villamor Street, Sta. Mesa, Manila (the “Subject Property”). In 1957, Spouses Valeriano and Genoveva Bueno engaged Atty. Eduardo Peralta to handle their personal and corporate legal affairs. In 1960, the Buenos gave the Subject Property to Atty. Peralta as partial consideration for services rendered. With the Buenos’ knowledge, Atty. Peralta and his family occupied the property from January 1962, paid real property taxes, and introduced substantial improvements. Atty. Peralta died on December 27, 1983. In 1990, Dr. Edgardo Peralta demanded execution of a proper deed of conveyance; the Buenos instead threatened ejectment. Subsequent Case Digest (G.R. No. 205810) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Arrangement Between Parties
- In 1957, Spouses Valeriano C. Bueno and Genoveva I. Bueno engaged Atty. Eduardo M. Peralta, Sr. as personal and business counsel of the Bueno family and their companies.
- In 1960, the Buenos gave Peralta their house and lot (TCT No. 47603, 3450 Magistrado Villamor St., Sta. Mesa, Manila) as partial consideration for his legal services. Peralta and family occupied the property from January 1962, introduced substantial improvements, and paid real property taxes.
- Breakdown and Litigation
- Atty. Peralta died on December 27, 1983. In 1990, Dr. Edgardo B. Peralta (one heir) wrote to the Buenos demanding execution of a proper Deed of Conveyance; the Buenos instead demanded surrender of possession and refused repeated demands. A physical intrusion and attack by Mr. Bueno on one Peralta heir led to a criminal complaint.
- In 1996, the Estate of Peralta filed a Complaint for specific performance in RTC Manila, Branch 37, praying for execution of the conveyance. The Buenos (later joined by Genoveva’s heirs, and after Mr. Bueno’s death in 2000) answered, invoking the Statute of Frauds, prescription, and impossibility due to encumbrances.
- After trial, the RTC (October 11, 2005) dismissed the complaint:
- Found no perfected contract—Peralta resigned in 1975, thus failed to serve until retirement (suspensive condition).
- Held action prescribed (six-year prescription for oral contracts).
- CA (August 31, 2012) reversed:
- Deemed the agreement an innominate (facio ut des) contract—Peralta rendered service (facio), the Buenos were to give property (des) upon retirement.
- Partial performance (possession, improvements, taxes) removed Statute of Frauds.
- Found Peralta served until retirement age; action is for quieting of title (imprescriptible).
- Ordered the Buenos to execute Deed of Conveyance or have title divested in favor of the Peralta estates.
- CA denied reconsideration (February 8, 2013). The Estate of Bueno filed a petition for review on certiorari (SC).
Issues:
- Is the alleged oral agreement to transfer real property in exchange for legal services enforceable despite the Statute of Frauds?
- Was the oral contract ratified or removed from the Statute of Frauds by partial performance, acceptance of benefits, and failure to object to parol evidence?
- Is the action barred by prescription or laches?
- Did the CA err in reversing the RTC and ordering the execution of the Deed of Conveyance?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)