Title
Gulam vs. Spouses Santos
Case
G.R. No. 151458
Decision Date
Aug 31, 2006
The complaint for Specific Performance was dismissed and the Contract to Sell rescinded due to the buyer's inability to prove full payment and submission of a forged receipt.
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Case Digest (G.R. No. 151458)

Facts:

  • Jallaludin Abdulrahman Gulam (petitioner) vs. spouses Catalino and Ricarda Santos (respondents).
  • Contract to Sell executed in January 1994 for a 72-square meter land in Sampaloc, Manila, priced at P1,700,000.00, including a townhouse to be built by the Santos spouses.
  • Payment terms: P500,000.00 upon construction start, another P500,000.00 in the second month, and the balance upon full payment, with an initial reservation fee of P50,000.00.
  • Gulam filed a complaint for Specific Performance in the RTC of Manila after two years, claiming he paid P2,050,000.00.
  • Santos spouses contested, asserting Gulam only paid P1,000,000.00 and counterclaimed for rescission due to non-fulfillment of payment obligations.
  • RTC dismissed Gulam's complaint, ordered rescission of the Contract to Sell, and ruled that P1,100,000.00 was forfeited as rental, along with damages and attorney's fees.
  • Gulam's appeal to the Court of Appeals affirmed the RTC's decision with modifications on damages, leading to a petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the factual findings of the RTC and CA, concluding that Gulam had not fully paid the stipulated price.
  • Gulam failed to provide sufficient evidence to support his claim of overpayment.
  • The Court upheld the lower courts' ruling that Gulam's testimony regarding his wife's payments was hea...(Unlock)

Ratio:

  • The Supreme Court noted that the determination of Gulam's payment status was a factual question, not typically reviewable under Rule 45, which allows for the review of legal questions only.
  • The RTC and CA thoroughly evaluated evidence, including testimonial and documentary, finding Gulam's overpayment claims unsubstantiated.
  • Discre...continue reading

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