G.R. No. 191618 - Macalintal vs. Presidential Electoral Tribunal

The dispute arises from a contract to sell (a conditional sale) between Myers Building Co., Inc. (vendor) and Maritime Building Co., Inc. (vendee), with Luzon Brokerage Co., Inc. as an interested or related party.
The contract, executed on April 30, 1949, provided for a down payment (P50,000.00) and subsequent monthly installments (P5,000.00) constituting a suspensive condition for the transfer of title.
Title was expressly reserved to Myers until the full and punctual payment of the purchase price was made, with the understanding that failure to meet the installment obligations would automatically cancel the contract and render the amounts paid as “rentals.”

Maritime, while simultaneously receiving P10,000.00 monthly in rental income from the lessee Luzon Brokerage Co., Inc., was contractually obliged to pay only P5,000.00 monthly as installments toward the balance of P950,000.00.
Despite having adequate funds—evidenced by the collection of rental earnings—Maritime willfully defaulted on the required installment payments beginning in March 1961.
The default was compounded by Maritime’s attempt to interpose an unrelated alleged personal promise by the late F.H. Myers regarding indemnification against a separate labor union liability, further complicating the breach.

Following the default on installments, Myers exercised its contractual right to cancel the agreement, retaining the sums previously paid as rentals.
Maritime sought judicial review and filed a motion for reconsideration. The first motion was thoroughly addressed and denied in the Court’s decision of January 31, 1972, and subsequently in the extended resolution of August 18, 1972.
Persisting with its challenge, Maritime filed a second motion for reconsideration on October 7, 1972, reiterating arguments previously dismissed and without presenting any novel grounds.

Over the prolonged litigation period (over six years), significant changes occurred in the Court’s composition, with many original members replaced while only a few remained from the earlier decisions.
The case procedural history underscores prolonged adjudication and the use of successive motions, which the Court viewed as an attempt to gain a favorable shift in judicial sentiment through incremental re-litigation.
The developments in statutory law—particularly the enactment of Republic Act No. 6552 (Maceda Law) in September 1972—reinforced the vendor’s contractual right of cancellation in transactions involving industrial and commercial real estate.

Whether Maritime’s second motion for reconsideration is entitled to reconsideration despite being a reiteration of previously raised and rejected arguments.

The issue of whether repeated pleadings aimed at reopening settled matters, hoping for a change in Court composition, should be entertained.
The sufficiency and novelty of the arguments presented in the second motion relative to the prior motions.

Whether the cancellation of the contract by Myers Building Co., Inc. is valid and enforceable given Maritime’s failure to observe its installment obligations.

Determination of whether Maritime’s non-payment constitutes a breach that automatically voids the contract.
Examination of the express contractual provision that retains title in the vendor’s possession until full payment is made.

The applicability of established jurisprudence and the statutory framework (notably the Maceda Law) in affirming the vendor’s rights and rejecting Maritime’s equitable arguments.

The relevance of the 39-year established doctrine on cancellation versus any new equitable considerations raised by Maritime.
The impact of the Maceda Law’s provisions on contracts involving industrial and commercial properties and its role in cementing the vendor’s cancellation right.