Case Digest (G.R. No. 180665) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Paulino Atienza, namely, Rufina L. Atienza, Anicia A. Ignacio, Roberto Atienza, Maura A. Domingo, Ambrocio Atienza, Maxima Atienza, Luisito Atienza, Celestina A. Gonzales, Regalado Atienza and Melita A. Dela Cruz v. Domingo P. Espidol (G.R. No. 180665, August 11, 2010), the petitioners, heirs of Paulino Atienza, held a 21,959-square-meter registered agricultural land under Emancipation Patent No. 416698 and Transfer Certificate of Title T-3971 in Valle Cruz, Cabanatuan City. On August 12, 2002, they and respondent Espidol executed a Kasunduan sa Pagbibili ng Lupa na may Paunang-Bayad covering the property at ₱130.00 per square meter (total ₱2,854,670.00), payable in three installments: ₱100,000.00 down payment on signing, ₱1,750,000.00 in December 2002, and ₱974,670.00 in June 2003. Espidol paid only the ₱100,000.00 down payment and a ₱30,000.00 broker’s commission. When the second installment fell due in December 2002, he failed to pay and offered an interim ₱500,00 Case Digest (G.R. No. 180665) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ownership and land
- Petitioners (heirs of Paulino Atienza) own a 21,959 sqm agricultural parcel in Valle Cruz, Cabanatuan City, covered by Emancipation Patent No. 416698 under P.D. 27.
- Their title reflects final grant status, signifying full amortization with the Land Bank as required by P.D. 27 and EO 228.
- Contract to sell with down payment
- On August 12, 2002, the parties executed a “Kasunduan sa Pagbibili ng Lupa na may Paunang-Bayad” stipulating a total price of ₱2,854,670 (₱130/sqm), payable:
- ₱100,000 upon signing;
- ₱1,750,000 in December 2002;
- ₱974,670 in June 2003.
- Respondent Espidol paid the ₱100,000 down payment and ₱30,000 broker’s commission but failed to pay the second installment due December 2002, offering instead ₱500,000 (claimed ₱800,000), which was refused.
- Proceedings below
- On February 21, 2003, the Atienzas filed in RTC Cabanatuan City (Civil Case No. 4451) a complaint to annul the contract and claim damages.
- Espidol admitted non-payment (citing a U.S. injunction affecting his funds), traveled to the Philippines offering ₱800,000, and argued that (a) non-payment in an installment contract is not breach but a ground for withholding transfer, (b) the remedy is specific performance, and (c) the action was premature since the last installment fell due in June 2003.
- RTC and CA decisions
- RTC (24 January 2005) held that:
- Non-payment was not a breach in an installment sale but merely suspended transfer;
- The Atienzas prematurely sought relief before the final installment’s due date;
- The petitioners failed to give the notarial cancellation notice required by R.A. 6552;
- Therefore, the contract remained valid and subsisting, and both parties were ordered to comply with its terms.
- Court of Appeals (31 August 2007 decision; 5 November 2007 resolution) affirmed the RTC and denied the Atienzas’ motion for reconsideration, rejecting their new theory that the sale was void under P.D. 27 and their arguments on R.A. 6552.
Issues:
- Whether the Atienzas validly sold land acquired under P.D. 27.
- Whether the Atienzas could cancel the contract for Espidol’s failure to pay the second installment when due.
- Whether the cancellation action was premature due to absence of the notarial notice required by R.A. 6552.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)