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
Case Digest (G.R. No. 151458)
Facts:
The case involves Jallaludin Abdulrahman Gulam as the petitioner and spouses Catalino and Ricarda Santos as the respondents. The events leading to the case began with a Contract to Sell executed in January 1994, wherein the Santos spouses agreed to sell a 72-square meter parcel of land in Sampaloc, Manila, to Gulam for a total price of P1,700,000.00. This price included a two-storey townhouse to be constructed by the respondents. The payment terms stipulated that Gulam would pay P500,000.00 upon the commencement of construction, another P500,000.00 in the second month, and the remaining balance upon full payment of the contract price, with an initial reservation fee of P50,000.00. The contract included a note acknowledging the receipt of P500,000.00 as a partial payment.
Two years after the contract was signed, Gulam filed a complaint for Specific Performance against the Santos spouses in the Regional Trial Court (RTC) of Manila, Branch 50, seeking to compel them to execute a final deed of sale, along with damages and costs. Gulam claimed he had paid a total of P2,050,000.00, which he detailed through various checks and receipts. However, the Santos spouses contested this, asserting that Gulam had only paid P1,000,000.00, excluding the reservation fee, and they counterclaimed for rescission of the contract due to Gulam's alleged failure to fulfill his payment obligations.
On September 17, 1998, the RTC dismissed Gulam's complaint and ordered the rescission of the Contract to Sell, citing that Gulam's failure to pay was not a mere casual breach but rather a significant breach tainted with fraud. The RTC ruled that the amount of P1,100,000.00, which the Santos spouses acknowledged receiving, was forfeited in their favor as rental for th...