Title
Supreme Court
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.

Case Digest (G.R. No. 187879)
Expanded Legal Reasoning Model

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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