Case Digest (G.R. No. 129107) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On March 22, 1985, Antonio Palao sold to Alfonso L. Iringan an undivided portion of Lot No. 992 in Tuguegarao, covered by TCT No. T-5790, for ₱295,000.00, payable: ₱10,000.00 on signing; ₱140,000.00 by April 30, 1985; and ₱145,000.00 by December 31, 1985. Iringan remitted only ₱40,000.00 of the second installment. On July 18, 1985, Palao declared the deed rescinded and refused further payments. Iringan’s counsel sought return of ₱50,000.00 paid, plus fees and interest, but Palao declined. After further failed negotiations, Palao filed on July 1, 1991 a Complaint for Judicial Confirmation of Rescission of Contract and Damages. In their Answer, Iringan and spouse contended the sale was perfected, demanding only the unpaid balance. On September 25, 1992, the Regional Trial Court (Branch I, Cagayan) decreed rescission, ordered cancellation of Iringan’s adverse claim, ejectment, and awarded compensation for use (net of 50% of amounts paid), moral (₱50,000.0 Case Digest (G.R. No. 129107) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Sale and Payment Terms
- On March 22, 1985, Antonio Palao (vendor) sold an undivided portion of Lot No. 992, Tuguegarao Cadastre (TCT No. T-5790) to Alfonso Iringan (vendee) for P295,000.00.
- The purchase price was payable: (a) P10,000 on signing; (b) P140,000 on or before April 30, 1985; and (c) P145,000 on or before December 31, 1985.
- When the second installment fell due, Iringan paid only P40,000.
- Notice of Rescission and Reimbursement Demand
- On July 18, 1985, Palao sent a letter declaring the contract rescinded and refusing further payments.
- On August 20, 1985, Iringan’s counsel (Atty. Aquino) replied, “not opposing revocation,” but claimed reimbursement of: (a) P50,000 cash paid; (b) P3,200 geodetic fee; (c) P500 attorney’s fee; and (d) interest on P53,700.
- On January 10, 1986, Palao rejected those reimbursement claims.
- Subsequent Negotiations and Arrears Claim
- On February 21, 1989, Iringan proposed either reimbursement of P50,000 or purchase of an equivalent land portion.
- Palao responded that Iringan owed P61,600 representing accrued rentals from October 1985 to March 1989.
- No settlement was reached.
- Judicial Proceedings Before the RTC
- On July 1, 1991, Palao filed a complaint for Judicial Confirmation of Rescission of Contract and Damages against Iringan and spouse.
- In their answer, the spouses argued the sale was consummated, the proper remedy was collection of balance, and they were willing to comply with the contract.
- Decisions of the RTC and CA
- RTC Decision dated September 25, 1992:
- Declared contract rescinded; canceled defendants’ adverse claim; ordered defendants to vacate.
- Ordered payment of P100,000 as compensation for use minus 50% of amounts paid; P50,000 moral damages; P10,000 exemplary damages; P50,000 attorney’s fees; and costs.
- Court of Appeals Decision dated April 30, 1997 (CA G.R. CV No. 39949):
- Affirmed RTC rescission, damages, and costs.
- Deleted award of attorney’s fees.
- Iringan filed a petition for review on certiorari before the Supreme Court, alleging:
- Error in affirming rescission.
- Error in finding his bad faith and awarding moral/exemplary damages.
Issues:
- Whether the contract of sale was validly rescinded.
- Whether the award of moral and exemplary damages against petitioner is proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)