Case Digest (G.R. No. L-22558) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Gregorio Araneta, Inc. (“GAI”) v. Philippine Sugar Estates Development Co., Ltd. (“PSEDC”), J.M. Tuason & Co., Inc., owner of the Sta. Mesa Heights subdivision in Quezon City, sold through GAI a 43,034.4 sqm parcel to PSEDC on July 28, 1950, under a deed of sale with mortgage. The contract required the buyer to build the Sto. Domingo Church and Convent and the seller to construct surrounding streets, including “Sto. Domingo Avenue” on the northeast side. PSEDC completed the church but GAI could not finish the northeast street because Manuel Abundo occupied part of the right‐of‐way. On May 7, 1958, PSEDC sued GAI and Tuason & Co. in the Court of First Instance of Manila for specific performance or, alternatively, damages. GAI answered, contending that its obligation lacked a definite period and that the action was premature. The trial court initially dismissed PSEDC’s complaint on May 31, 1960, but on reconsideration fixed a two‐year period for GAI to comply. GAI appealed. The Case Digest (G.R. No. L-22558) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- J.M. Tuason & Co., Inc. (owner) – Torrens titleholder of Sta. Mesa Heights Subdivision in Quezon City
- Gregorio Araneta, Inc. (agent and co-seller) – acted on behalf of Tuason & Co.
- Philippine Sugar Estates Development Co., Ltd. (buyer)
- Contract of Sale (July 28, 1950)
- Subject: Portion of 43,034.4 sqm sold for ₱430,514.00
- Buyer’s obligation: Build Sto. Domingo Church and Convent on the parcel
- Seller’s obligation: Construct streets on NE, NW, SW sides; name NE street “Sto. Domingo Avenue”
- Acknowledgment of existing squatter occupation on the NE portion
- Performance and Initial Litigation
- Buyer completed the church and convent; seller commenced but did not finish NE street due to squatter (Manuel Abundo) refusal to vacate
- May 7, 1958 – Buyer sued Tuason & Co. and Gregorio Araneta, Inc., seeking specific performance or damages for failure to construct the streets
- Defendants’ main defense: obligation lacked a definite period, rendering specific performance premature
- Proceedings in the Court of First Instance (Manila)
- May 31, 1960 – Trial court dismissed the complaint for prematurity
- Buyer’s motion for reconsideration prayed for court to fix a performance period
- July 16, 1960 – Trial court granted reconsideration, fixing two years from notice to comply
- August 16, 1960 – Motion for reconsideration by Gregorio Araneta, Inc. denied; it appealed
- Court of Appeals Decision (Dec. 27, 1963)
- Held that fixing a period was within the pleadings and not a change of theory
- Affirmed with modification: two years from finality to construct streets on NE, NW, SW sides
- Gregorio Araneta, Inc. filed a petition for certiorari to the Supreme Court
Issues:
- Whether the courts below had authority under Article 1197, Civil Code, to fix a two-year period for performance when the contract allegedly provided only a “reasonable time.”
- Whether the two-year period fixed was supported by the pleadings or the circumstances “probably contemplated by the parties.”
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)