Title
Joseph vs. Spouses Joseph
Case
G.R. No. 234384
Decision Date
Apr 26, 2021
A dispute arises between a petitioner and respondents over the purchase of a parcel of land, with the petitioner claiming full payment and demanding the execution of a deed of absolute sale, but failing to provide sufficient evidence to support his claim, resulting in the Supreme Court ruling against him and denying the award of moral damages and attorney's fees.
Font Size

Case Digest (G.R. No. 234384)

Facts:

  • The dispute is between petitioner Eliseo N. Joseph and respondents Spouses Josefina and Danilo Joseph.
  • The conflict centers on the purchase of a 225-square-meter parcel of land in Balangcas, Valenzuela City, covered by TCT No. V-46412.
  • On January 15, 2002, the parties agreed to sell the property for P225,000.00, with a downpayment of P100,000.00 and the remaining P125,000.00 to be paid within a year.
  • Petitioner claimed he fully paid the agreed amount and demanded the execution of a deed of absolute sale, which was signed only by Josefina Joseph.
  • Danilo Joseph refused to sign unless an additional P30,000.00 was paid, claiming it was for property improvements.
  • Petitioner filed a complaint for specific performance and damages on February 23, 2005.
  • The RTC Branch 172 of Valenzuela City ruled in favor of the respondents, ordering the petitioner to pay the additional P30,000.00 and awarding moral damages and attorney's fees to the respondents.
  • The CA affirmed the RTC's decision with modifications, leading to the present petition for review on certiorari under Rule 45.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, affirming the CA's decision with modifications.
  • The Court deleted the award of moral damages and attorney's fees in favor of the respondents.
  • Petitioner Eliseo Joseph was ordered to pay the respondents the unpaid purchase price of P30,000.00, with...(Unlock)

Ratio:

  • The Supreme Court held that the petition lacked merit as it raised factual issues, which are not within the scope of a petition for review on certiorari under Rule 45.
  • The Court emphasized that it is not a trier of facts and that the factual findings of the lower courts are generally accorded finality.
  • The Court found that the petitioner failed to prove full payment of the pu...continue reading

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.

© 2024 Jur.ph. All rights reserved.