Case Digest (G.R. No. 185798)
Facts:
- Petitioners: Fil-Estate Properties, Inc. and Fil-Estate Network, Inc.
- Respondents: Spouses Conrado and Maria Victoria Ronquillo.
- Respondents purchased an 82-square meter condominium unit at Central Park Place Tower, Mandaluyong City for P5,174,000.00.
- On August 29, 1997, they executed a Reservation Application Agreement and paid a reservation fee of P200,000.00.
- They made a down payment of P1,552,200.00 and monthly amortizations of P63,363.33 until September 1998.
- Construction ceased, prompting respondents to stop payments after totaling P2,198,949.96.
- Respondents demanded a full refund with interest through two letters, which went unanswered.
- Filed a Complaint for Refund and Damages before the Housing and Land Use Regulatory Board (HLURB).
- HLURB issued an Order of Default against petitioners on October 21, 2000, for failing to respond.
- Petitioners attributed construction delays to the 1997 Asian financial crisis and denied fraudulent conduct.
- On June 13, 2002, HLURB Arbiter ruled in favor of respondents, ordering a refund plus interest, moral damages, attorney's fees, and an administrative fine.
- Petitioners' appeals to the HLURB Board of Commissioners and the Office of the President were unsuccessful.
- The Court of Appeals affirmed the previous decisions, leading petitioners to file a petition for review with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Asian financial crisis did not excuse the petitioners from their contractual obligations.
- The Court affirmed the lower courts' decisions, ordering a refund of the total amount paid by the respondents, including interest.
- The Court modified the legal interest to 6% per annum, effective from the date...(Unlock)
Ratio:
- The Court determined that the Asian financial crisis was not a fortuitous event exempting the petitioners from their contractual duties.
- The failure to develop the condominium project was a substantial breach of contract, allowing respondents to rescind the agreement and seek reimbursement.
- Cited Article 1191 of the New Civil Code, which permits rescission in reciprocal obligations when one party...continue reading
Case Digest (G.R. No. 185798)
Facts:
The case involves Fil-Estate Properties, Inc. and Fil-Estate Network, Inc. as petitioners and spouses Conrado and Maria Victoria Ronquillo as respondents. The events leading to the case began when the respondents purchased an 82-square meter condominium unit at Central Park Place Tower in Mandaluyong City for a total pre-selling price of P5,174,000.00. On August 29, 1997, the respondents executed a Reservation Application Agreement and paid a reservation fee of P200,000.00. Subsequently, they made a down payment of P1,552,200.00 and continued to pay monthly amortizations of P63,363.33 until September 1998. However, upon discovering that construction had ceased, the respondents halted their payments. They claimed to have paid a total of P2,198,949.96 and demanded a full refund with interest through two letters, which went unanswered. Consequently, they filed a Complaint for Refund and Damages before the Housing and Land Use Regulatory Board (HLURB), seeking reimbursement of their payments, moral damages, attorney's fees, and other litigation expenses.
On October 21, 2000, the HLURB issued an Order of Default against the petitioners for failing to respond to the complaint. The petitioners later filed a motion to lift the order, attributing the construction delay to the 1997 Asian financial crisis and denying any fraudulent conduct. On June 13, 2002, the HLURB Arbiter ruled in favor of the respondents, ordering the petitioners to refund the total amount paid, plus interest, moral damages, attorney's fees, and an administrative fine for violating PD 957. The petitioners appealed this decision, but the HLURB Board of Commissioners and later the Office of ...