G.R. No. 135929 - Limson vs. Court of Appeals

Parties, Property and Initial Agreement
Petitioner Lourdes Ong Limson filed a complaint on 14 May 1979, alleging that in July 1978 spouses Lorenzo de Vera and Asuncion Santos-de Vera (through agent Marcosa Sanchez) offered to sell her a 48,260 sqm parcel in Barrio San Dionisio, Parañaque at P 34.00/sqm.
On 31 July 1978 she paid P 20,000 “earnest money” (receipt issued, 10-day option period), learned of an existing mortgage, and agreed to settle it.

Attempts to Consummate Sale
Meetings were set on 5 and 11 August 1978 to finalize the sale; petitioner claimed respondents’ failures (missing parties, unpaid back taxes) prevented formalization.
On 23 August 1978 petitioner gave three checks totaling P 36,170 for back taxes and quitclaims; respondents acknowledged receipt.

Third-Party Sale and Adverse Claim
On 15 September 1978 spouses sold the property to Sunvar Realty (represented by Tomas Cuenca, Jr.); TCT No. S-72377 issued 26 September.
Petitioner filed an Affidavit of Adverse Claim on 15 September; annotation entered on TCTs.

Proceedings Below
Regional Trial Court (30 June 1993) ruled in favor of petitioner: annulled the Sunvar sale, canceled TCT S-72377, restored TCT S-72946, ordered spouses to sell to petitioner upon balance payment, and awarded P 50,000 attorney’s fees.
Court of Appeals (18 May 1998) reversed: lifted adverse claim, ordered petitioner to pay nominal/exemplary damages and attorney’s fees to Sunvar (P 100,000 total) and spouses (P 35,000), denied reconsideration (19 October 1998).

Whether the agreement between petitioner and respondent spouses was a perfected contract to sell or merely an option contract.
Whether Sunvar Realty purchased in good faith or with notice of petitioner’s rights.
Whether respondents are entitled to nominal/exemplary damages and attorney’s fees.