Title
Heirs of Salas, Jr. vs. Laperal Realty Corp.
Case
G.R. No. 135362
Decision Date
Dec 13, 1999
Heirs of Salas, Jr. sued Laperal Realty and buyers over land sales; arbitration clause binds heirs and Laperal but not third-party buyers.
A

Case Digest (G.R. No. 135362)

Facts:

  • Parties and Background
    • Augusto L. Salas, Jr. (Salas, Jr.) was the registered owner of a 1,484,354-square-meter tract of land in Lipa City, Batangas.
    • On May 15, 1987, Salas, Jr. entered into an Owner-Contractor Agreement with Laperal Realty Corporation for horizontal construction services.
    • On September 23, 1988, Salas, Jr. executed a Special Power of Attorney in favor of Laperal Realty to manage and supervise the sale of his land.
    • On June 10, 1989, Salas, Jr. disappeared during a business trip and was declared presumptively dead on December 12, 1996, by the RTC of Makati City.
  • Subdivision, Sales, and Pre-trial Proceedings
    • Laperal Realty subdivided the land and sold parcels to various buyers:
      • Rockway Real Estate Corporation and South Ridge Village, Inc. (February 22, 1990)
      • Spouses Thelma D. Abrajano and Gregorio Abrajano, spouses Virginia D. Lava and Rodel Lava, and Oscar Dacillo (June 27, 1991)
      • Eduardo A. Vacuna, Florante de la Cruz, and Jesus Vicente B. Capellan (June 4, 1996)
    • On February 3, 1998, petitioners (heirs of Salas, Jr.) filed in RTC Lipa City Civil Case No. 98-0047 a Complaint for declaration of nullity of sale, reconveyance, cancellation of contract, accounting, and damages.
    • On April 24 and May 5, 1998, Laperal Realty and several lot buyers moved to dismiss for failure to submit disputes to arbitration under Article VI of the Owner-Contractor Agreement.
    • On August 9, 1998, the trial court dismissed the petitioners’ complaint for non-compliance with the arbitration clause, ordering arbitration.

Issues:

  • Whether the petitioners’ causes of action for rescission, reconveyance, cancellation of contract, accounting, and damages arise from the Owner-Contractor Agreement and are therefore subject to its arbitration clause.
  • Whether the lot buyers—who were not parties, assigns, or heirs under the Agreement—are bound by the arbitration stipulation.
  • Whether the failure to arbitrate warranted dismissal of the petitioners’ complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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