Case Digest (G.R. No. 130864)
Facts:
Maria L. Harold v. Agapito T. Aliba, G.R. No. 130864, October 02, 2007, Supreme Court Second Division, Quisumbing, J., writing for the Court. Petitioner is Maria L. Harold; respondent is Agapito T. Aliba.In January 1993 Harold engaged respondent, a geodetic engineer, to perform a relocation survey and a consolidation‑subdivision of parcels in Pico, La Trinidad, Benguet (including a parcel of Harold's sister). Aliba was paid P4,050 but failed to return the certificates of title for over a year despite repeated demands. Sometime in January 1994 Aliba had Harold and her husband sign a document he said was needed for the subdivision; they signed without reading it. On April 18, 1994 construction materials arrived at the lot and Harold learned Aliba had sold the lot to a third person.
Aliba later offered P400,000 then P500,000; on May 3, 1994 Harold agreed to accept P500,000 as partial payment (the lot's alleged aggregate value was P1,338,000). She signed an acknowledgment and other papers that purportedly showed full settlement for a lesser amount. Harold discovered that Aliba had caused a deed of sale (the January document) to be used to transfer title to him and made it appear she had sold the lot for P80,000.
The dispute went to barangay conciliation. On June 8, 1994 the parties agreed that Aliba would pay an additional P75,000; Aliba tendered P70,000 that day and Harold accepted, with an acknowledgment receipt and minutes attested by the Lupon chairman. On June 9, 1994 Aliba returned with the remaining P5,000 but Harold refused it and sought court action; a Certification to File Action was issued June 29, 1994, and Harold filed suit in the Municipal Trial Court (MTC) of La Trinidad.
In his Answer Aliba moved to dismiss, asserting an amicable settlement and substantial compliance therewith. On September 4, 1995 the MTC granted the motion to dismiss, finding there was a meeting of minds and substantial fulfillment; it ordered dismissal but directed Aliba to tender the remaining P5,000 when the order became final. The Regional Trial Court (RTC), Branch 63, La Trinidad affirmed the MTC Order in an Order dated February 20, 1996. The Court of Appeals, in CA‑G.R....(Pro-only)
Issues:
- Did the lower courts err in dismissing Harold's complaint on the ground that the parties had arrived at an amicable settlement before the barangay court (i.e., was there a meeting of minds)?
- If a meeting of minds existed, did the acknowledgment receipt and minutes constitute substantial compliance with Section 411 of Republic Act No. 7160 (the Local Government Code)?
- Did Harold's refusal to accept the remaining P5,000 and insistence on elevating the case to court constitute a valid repudiation of the amicable settlemen...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)