Title
Supreme Court
Luxuria Homes, Inc., and/or Aida M. Posadas vs. Honorable Court of Appeals, James Builder Construction and/or Jaime T. Bravo
Case
G.R. No. 125986
Decision Date
Jan 28, 1999
Aida Posadas' refusal to finalize a management contract with James Builder led to a default judgment in favor of the respondents, with the Supreme Court partially granting Posadas' appeal and modifying the damages awarded.

Case Digest (G.R. No. 125986)
Expanded Legal Reasoning Model

Facts:

  • Ownership and Negotiations
    • Petitioner Aida M. Posadas and her two minor children co-owned a 1.6-hectare property in Sucat, Muntinlupa, occupied by squatters.
    • Posadas authorized private respondent Jaime T. Bravo to negotiate with squatters for their removal on May 3, 1989.
    • Respondent Bravo engaged with the squatters while negotiations proceeded.
  • Transfer and Incorporation
    • On December 11, 1989, Posadas and her children transferred the property to petitioner Luxuria Homes, Inc. through a Deed of Assignment, for organizational and tax purposes.
    • Jaime T. Bravo witnessed the Deed of Assignment and the Articles of Incorporation of Luxuria Homes, Inc.
  • Breakdown of Relationship and Litigation
    • By 1992, Posadas and Bravo's relationship soured due to disagreements over management contracts for property development.
    • Bravo demanded payment of P1,708,489.00 for relocation of squatters, architectural design, site development plans, survey, and fencing.
    • Posadas refused payment, leading to a complaint for specific performance filed by James Builder Construction and Jaime T. Bravo against Posadas and Luxuria Homes, Inc. in September 1992.
  • Trial Court Proceedings
    • Posadas was declared in default on September 27, 1993, and private respondents presented evidence ex-parte.
    • Trial court ordered Posadas and Luxuria Homes, Inc. to pay various amounts including the balance of P1,708,489.00 for services, P1,500,000.00 actual damages, moral and exemplary damages, attorney's fees, and costs.
    • Posadas was further ordered to execute the management contract.
  • Appeals
    • The Court of Appeals affirmed the trial court’s decision with modification: deleting moral damages (corporate plaintiff) and reducing exemplary damages to P50,000.00.
    • This Court initially denied due course to petitioners' review but later reinstated it after reconsideration, deleting exemplary damages and attorney's fees and reducing actual damages to P500,000.00.

Issues:

  • Whether private respondents sufficiently proved their claims ex-parte after petitioners’ default.
  • Whether Luxuria Homes, Inc. could be held liable jointly and solidarily for the obligations entered by Posadas.
  • Whether petitioners can be compelled to execute a management contract with private respondents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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