Case Digest (G.R. No. L-16530)
Facts:
In MAMERTO LAUDICO and FRED. M. HARDEN vs. MANUEL ARIAS RODRIGUEZ et al. (43 Phil. 270, decided March 31, 1922), plaintiffs-appellants Mamerto Laudico and Fred M. Harden sued defendants-respondents Vicente Arias and his co-owners of the buildings Nos. 205–221 on Carriedo Street in Manila to compel execution of a lease contract. On February 5, 1919, Arias, on behalf of himself and the other owners, sent Laudico a written option to lease, enclosing a tentative lease agreement and inviting Laudico to find a lessee. Laudico proposed Harden as the tenant and forwarded additional conditions while requesting clarifications on certain provisions. Negotiations proceeded by correspondence and personal conferences but no definitive accord was reached. On March 6, 1919, at 11:25 a.m., Arias dispatched a letter revoking the lease offer. At 2:53 p.m. of the same day, he received Laudico’s letter stating acceptance of the amended terms. Unaware of the acceptance when heCase Digest (G.R. No. L-16530)
Facts:
- Parties and Property
- Plaintiffs-Appellants: Mamerto Laudico and Fred M. Harden, desiring to lease a building.
- Defendants-Appellees: Vicente Arias (on behalf of co-owners Manuel Arias Rodriguez et al.), owners of buildings Nos. 205–221 Carriedo Street.
- Offer and Preliminary Contract
- February 5, 1919: Arias transmitted to Laudico an option to lease the building, enclosing a tentative written lease contract with specified conditions.
- Laudico proposed Fred M. Harden as lessee; negotiations ensued by correspondence and personal interviews, including added conditions, counter-proposals, and requests for clarification.
- Acceptance and Revocation Timing
- March 6, 1919, 11:25 a.m.: Arias sent Laudico a letter withdrawing the offer, delivered by messenger to Laudico’s office.
- March 6, 1919, 2:53 p.m.: Arias received Laudico’s letter of acceptance, in which all amended and supplemented propositions were accepted.
- Litigation
- Plaintiffs sued for specific performance, praying that defendants be compelled to execute the lease contract.
Issues:
- Was there a binding contract of lease between the parties given the sequence of withdrawal and acceptance?
- Could the offer to lease be validly revoked by Arias before he received actual knowledge of Laudico’s acceptance?
- Does the general doctrine requiring notice of revocation to the offeree apply under the Civil Code’s provision on acceptance by letter?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)