Case Digest (G.R. No. 204289) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Fernando Mancol, Jr. v. Development Bank of the Philippines (G.R. No. 204289, November 22, 2017), the petitioner, Fernando Mancol, Jr., executed a Special Power of Attorney (SPA) in favor of his father, Fernando Mancol, Sr., to negotiate the purchase of a residential lot with two-storey building in Calbayog City, covered by TCT No. 2041. On October 13, 2004, during DBP’s Invitation to Bid for Negotiated Sale, Mancol, Sr. signed the Negotiated Offer to Purchase and paid the initial P265,200, followed by a balance of P1,060,800 on December 10, 2004. Concurrently, DBP allegedly agreed orally to arrange for the transfer of title in Mancol, Jr.’s name (including capital gains tax and documentary stamp tax) and to eject the occupants. Mancol, Jr. deposited P99,450 for those taxes, but by 2006 DBP declined to fulfill its verbal undertaking, returned the documents and the P99,450 check, and denied any obligation. Mancol, Jr. instituted Civil Case No. 923 before the RTC of Calbayog Ci Case Digest (G.R. No. 204289) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Sale and Special Power of Attorney
- On October 13, 2004, Development Bank of the Philippines (DBP) invited bids for a negotiated sale of a residential lot with two-storey building in Calbayog City (TCT No. 2041; TD Nos. 990100600931 & 990100600479), at a base price of ₱1,326,000.
- Fernando Mancol, Jr. executed a Special Power of Attorney (SPA) appointing his father, Fernando Mancol, Sr., to represent and negotiate the sale. Under the SPA, Mancol, Sr. signed the Negotiated Offer to Purchase and Sale Rules and Procedures.
- Performance of the Sale Contract
- Mancol, Sr. paid an initial ₱265,200 (O.R. No. 3440018) and later the balance of ₱1,060,800 (O.R. No. 3440451). DBP executed a Deed of Absolute Sale in favor of Mancol, Jr.
- On December 21, 2004, Mancol, Jr. deposited ₱99,450 for capital gains tax (CGT) and documentary stamp tax (DST) (O.R. No. 3440537).
- Alleged Oral Undertakings and Reneging by DBP
- Petitioner alleges that, during negotiations, DBP verbally agreed to arrange the transfer of title in his name (including tax payments) and to eject occupants. In 2006 DBP returned all documents and issued a Manager’s Check for ₱99,450, repudiating any obligation.
- Petitioner’s letters to DBP (Feb. 21, 2006 & June 2, 2006) and to BIR (May 15, 2006) prompted BIR’s tax computation of ₱160,700.88 (May 24, 2006), which later increased to ₱183,553.61 by March 2007.
- Proceedings Before the Regional Trial Court (RTC)
- On August 24, 2006, Mancol, Jr. filed a Complaint for damages for breach of contract, seeking return of the ₱99,450 check, payment of tax surcharges, damages and attorney’s fees. DBP counter-claimed for unpaid ejectment expenses and other damages.
- The RTC declared DBP in default (Feb. 20, 2007). Trial ensued with testimonies from DBP’s agent Rodel Villanueva and Mancol, Sr. On April 14, 2008, the RTC ordered DBP to return ₱99,450, pay tax surcharges from June 12, 2005, and award ₱15,000 attorney’s fees.
- Subsequent RTC and Court of Appeals (CA) Actions
- DBP’s motion for reconsideration was granted on June 13, 2008, dismissing the complaint. Petitioner’s own reconsideration failed (Nov. 4, 2008), though the RTC modified to order return of ₱99,450 with 6% interest from December 21, 2004. DBP’s further motion was denied (Apr. 17, 2009).
- Both parties appealed to the CA. On February 22, 2012, the CA denied both appeals and affirmed the RTC’s orders. Motions for reconsideration were denied on September 27, 2012. Petitioner then filed this Petition for Review on Certiorari.
Issues:
- Whether the CA erred in admitting and giving weight to the testimonies of Villanueva and Mancol, Sr., which allegedly established a subsequent oral agreement contradicting the written sale agreement.
- Whether petitioner is entitled to moral and exemplary damages, attorney’s fees and costs of suit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)