Case Digest (G.R. No. 78623) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Juan San Andres (Victor S. Ziga) and Salvacion S. Tria v. Vicente Rodriguez, decided May 31, 2000 under G.R. No. 135634, the late Juan San Andres was registered owner of Lot No. 1914-B-2 in Liboton, Naga City. On September 28, 1964, he executed a Deed of Sale conveying 345 sqm thereof to Vicente S. Rodriguez for ₱2,415.00. After Andres died on May 5, 1965, Ramon San Andres was appointed judicial administrator of the estate and commissioned a survey. The engineer’s consolidated plan revealed Rodriguez had actually occupied an adjoining 509 sqm. On July 27, 1987, the administrator demanded Rodriguez vacate the 509 sqm portion; Rodriguez refused, producing a September 29, 1964 receipt for a ₱500.00 advance for “a residential lot adjoining his previously paid lot on three sides,” with the balance at ₱15.00 per sqm to be paid within five years upon formal deed of sale and survey. Rodriguez later deposited ₱7,035.00 representing the balance. The administrator filed a recov Case Digest (G.R. No. 78623) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and parties
- Juan San Andres was the registered owner of Lot No. 1914-B-2 in Liboton, Naga City. On September 28, 1964, he sold a 345 sqm portion to Vicente Rodriguez for ₱2,415, evidenced by a Deed of Sale.
- Juan San Andres died on May 5, 1965. Ramon San Andres was appointed judicial administrator of the estate (SP No. R-21, RTC, Branch 19). A consolidated estate plan and a sketch of the sold 345 sqm were prepared by Engr. Jose Peñero, revealing a 509 sqm encroachment by Rodriguez.
- Demand and complaint
- On July 27, 1987, the administrator demanded Rodriguez vacate the alleged encroachment. Rodriguez refused, asserting he purchased the additional 509 sqm on September 29, 1964.
- On November 24, 1987, the administrator filed an action for recovery of possession of the 509 sqm portion (Civil Case No. 87-1335).
- Respondent’s position and evidence
- In his re-amended answer (Feb. 6, 1989), Rodriguez alleged a second sale of 509 sqm at ₱15/sqm, down-payment of ₱500 (Exh. 2), balance due in five years after survey and formal deed. He took possession in 1964 and made improvements.
- Exhibit 2 (“receipt”): P500 advance payment; price ₱15 per sqm; full payment after survey within five years; survey costs borne by Rodriguez.
- Exhibit 3 (Mar. 30, 1966 letter): Ramon San Andres requested ₱300; received ₱100 (signed by Enrique del Castillo).
- Rodriguez later deposited ₱7,035 in court representing the balance for 509 sqm. During the action both Ramon San Andres and Vicente Rodriguez died; substituted by their successors.
- Trial court proceedings
- Petitioner’s witnesses: Engr. Peñero testified on the 509 sqm encroachment; Ricardo San Andres denied prior claims and knowledge of Exh. 2 but recognized Exh. 3’s signature.
- Respondent’s witness Bibiana Rodriguez (widow) testified on the 1964 purchase, payments (₱500, ₱100, deposit ₱7,035), continuous possession pending survey.
- Judgments below
- RTC (Sept. 20, 1994): Held Exhibit 2 lacked sufficient description of the 509 sqm, no valid sale; ordered a new contract.
- CA (Apr. 21, 1998): Reversed. Found object determinable, perfected conditional sale, valid consignment. Ordered acceptance of ₱7,035, execution of formal deed for 509 sqm, payment of ₱50,000 damages, ₱10,000 attorney’s fees, and costs.
Issues:
- Whether the purported sale receipt (Exh. 2) lacks an essential element—an object certain and sufficiently described.
- Whether petitioner is obliged to honor the contract to sell despite non-fulfillment of the condition on payment of the balance.
- Whether the deposit of ₱7,035 in court constitutes valid consignation despite non-compliance with mandatory requirements.
- Whether laches and prescription bar respondent from enforcing the purported contract after 24 years.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)