Case Digest (G.R. No. L-2077)
Facts:
- The consolidated cases involve two separate transactions with Caridad Estates of Cavite, Inc.
G.R. No. L-2077:
- Plaintiffs: Guillermina R. Miranda and Antero Miranda.
- Date of Contract: September 13, 1941.
- Subject: Purchase of a parcel of land in Cavite City for P1,685.00.
- Payment Terms: Installments over one year.
- Contract Clause: Failure to pay within 30 days of due date results in forfeiture and annulment, with payments considered as rental.
- Payments Made: P200.00 on contract date, P100.00 on October 29, 1941.
- Issue: Subsequent payments halted due to war.
- Action by Caridad Estates: Rescinded contract on July 8, 1943, sold land to Gregorio Alvarez.
- Plaintiffs' Action: Post-liberation, sought to annul Alvarez's title, compel acceptance of balance, and claim P800.00 damages.
G.R. No. L-2121:
- Plaintiff: Paulino Aspuria.
- Date of Contract: April 14, 1940.
- Subject: Purchase of a 388 square meter parcel of land for P1,358.00.
- Payments Made: P638.00 by December 6, 1941.
- Balance: P720.00.
- Action by Caridad Estates: Canceled contract on March 27, 1944, sold land to Perpetuo de Jesus, who sold it to Rodolfo Bonanza.
- Deed of Sale: Executed in favor of Bonanza on November 8, 1944, with a Transfer Certificate of Title issued.
- Court of First Instance of Cavite: Ruled in favor of plaintiffs, stating rescissions were ineffective without notarial or judicial demand and unwarranted under contract terms.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the judgments of the Court of First Instance of Cavite.
- The court ruled in favor of Caridad Estates of Cavite, Inc....(Unlock)
Ratio:
- The contracts had clear stipulations allowing Caridad Estates to rescind and forfeit payments as rental in case of default.
- The court referenced the case of Caridad Estates Subdivision Inc. v. Pablo Santero, which upheld simila...continue reading
Case Digest (G.R. No. L-2077)
Facts:
The consolidated cases involve two separate transactions with Caridad Estates of Cavite, Inc. In G.R. No. L-2077, plaintiffs Guillermina R. Miranda and Antero Miranda entered into a contract on September 13, 1941, to purchase a parcel of land in Cavite City for P1,685.00, payable in installments over one year. The contract stipulated that failure to make payments within 30 days of the due date would result in forfeiture and annulment of the contract, with all payments made considered as rental. The plaintiffs paid P200.00 on the contract date and P100.00 as the first installment on October 29, 1941. Due to the outbreak of war, subsequent payments were not made. On July 8, 1943, Caridad Estates unilaterally rescinded the contract and sold the land to Gregorio Alvarez. The plaintiffs, after the liberation, filed an action to annul the title issued to Alvarez, compel Caridad Estates to accept the balance of the purchase price, and claim damages of P800.00.
In G.R. No. L-2121, plaintiff Paulino Aspuria entered into a similar contract on April 14, 1940, for a parcel of land measuring 388 square meters at P1,358.00. Aspuria paid P638.00 by December 6, 1941, leaving a balance of P720.00. Cari...