Facts:
The petitioners are the
Heirs of Juan San Andres (Victor S. Ziga) and
Salvacion S. Tria, and the respondent was
Vicente S. Rodriguez; the events occurred in Naga City beginning with sales in September 1964 and leading to litigation in the Regional Trial Court, Branch 19, Civil Case No. 87-1335. On September 28, 1964, the late Juan San Andres sold a 345-square meter portion of Lot No. 1914-B-2 to
Vicente Rodriguez by Deed of Sale for P2,415.00; on September 29, 1964 San Andres signed a receipt (Exh. 2) acknowledging P500.00 as an advance for an adjoining residential lot described as adjoining the previously paid lot on three sides at P15.00 per square meter, with the full consideration to be computed after survey and payable within five years from the execution of a formal deed of sale. After the vendor’s death in May 1965, Ramon San Andres was appointed judicial administrator and later caused a survey that showed respondent had occupied an additional 509 square meters of the titled tract; by letter dated July 27, 1987 the administrator demanded vacatur, and on November 24, 1987 he filed an action for recovery of possession of the 509-square meter portion. Respondent denied the complaint, asserted purchase of the 509-square meter portion, produced Exh. 2 and a March 30, 1966 correspondence from Ramon San Andres (Exh. 3), and deposited P7,035.00 in court as the balance of the purchase price; the trial court, presided by Judge Gregorio E. Manio, Jr., rendered judgment for petitioners on September 20, 1994 holding that Exh. 2 failed to sufficiently identify the object of sale, but the Court of Appeals reversed on April 21, 1998, finding the object determinable, declaring the sale perfected and absolute, ordering acceptance of the deposit, execution of a deed of sale in favor of
Vicente Rodriguez, and awarding P50,000.00 damages and P10,000.00 attorneys’ fees to respondent; petitioners sought review before the Court and raised assignments of error contesting the determinacy of the object, the alleged non-fulfillment of the payment condition, the validity of consignation, and the applicability of laches and prescription.
Issues:
Was the receipt dated September 29, 1964 (Exh. 2) a valid and sufficiently determinate
contract of sale for the 509-square meter portion of Lot No. 1914-B-2? Was the stipulation that the full consideration be computed after survey and be payable within five years from the execution of a formal deed of sale a condition that prevented perfection or enforceability of the sale? Was the deposit of P7,035.00 in court properly treated as a payment to be accepted and a basis to compel execution of the deed of sale rather than a defective
consignation? Are petitioners barred by
prescription or
laches from enforcing their possessory claim against the respondent’s heirs?
Ruling:
Ratio:
Doctrine: