Case Digest (G.R. No. 210215) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 22, 2008, petitioners Rogelio S. Nolasco, Nicanora N. Guevara, Leonarda N. Elpedes, heirs of Arnulfo S. Nolasco, and Remedios M. Nolasco (represented by Elenita M. Nolasco) entered into a Contract to Sell a 165,775–square meter parcel in Barangay San Isidro, Rodriguez, Rizal (Original Certificate of Title No. 152) with respondents Celerino S. Cuerpo, Joselito Encabo, Joseph Ascutia, and Domilo Lucenario. The purchase price was ₱33,155,000.00, composed of an ₱11,604,250.00 down payment (inclusive of a ₱2,000,000.00 reservation fee) and thirty‐six monthly amortizations of ₱598,632.00 each, payable by post‐dated checks. The contract stipulated that petitioners would, within 90 days, transfer the title from Edilberta N. Santos to their names at their expense, failing which respondents could effect the transfer and charge related costs to petitioners. Respondents were not to possess the land until full payment, and petitioners would remit title upon full settlement. In Novemb Case Digest (G.R. No. 210215) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract to Sell
- On July 22, 2008, petitioners Rogelio S. Nolasco, Nicanora N. Guevara, Leonarda N. Elpedes, heirs of Arnulfo S. Nolasco, and Remedios M. Nolasco, represented by Elenita M. Nolasco, entered into a Contract to Sell with respondents Celerino S. Cuerpo, Joselito Encabo, Joseph Ascutia, and Domilo Lucenario over a 165,775-sqm parcel in Barangay San Isidro, Rodriguez, Rizal (OCT No. 152).
- Key terms:
- Total purchase price ₱33,155,000 – down payment ₱11,604,250 (including ₱2,000,000 earnest money) and balance ₱21,550,750 payable in 36 monthly installments of ₱598,632 via post-dated checks.
- Dishonor of any check entitles petitioners to forfeit payments, cancel contract without judicial recourse, and pursue legal action.
- No possession by respondents until full payment.
- Petitioners to cause transfer of title from Edilberta N. Santos to their names within 90 days; upon failure, respondents may effect transfer at petitioners’ expense and charge costs against installments.
- Upon full payment, petitioners to transfer title to respondents.
- Demand for Rescission and Trial
- On November 7, 2008, respondents sent a letter seeking rescission of the contract for alleged financial difficulties and refund of ₱12,202,882.
- After no response, respondents filed a complaint on November 21, 2008 for rescission and restitution. Petitioners countered that respondents unilaterally cancelled the contract and that financial difficulty is not a statutory ground for rescission. Petitioners were declared in default for failure to file a pre-trial brief, prompting an ex parte presentation of respondents’ evidence.
- RTC and CA Proceedings
- RTC (March 1, 2010) ordered rescission of the contract and return of all payments and post-dated checks, finding petitioners’ failure to effect the 90-day title transfer a substantial breach under Art. 1191, Civil Code.
- CA (June 17, 2013) affirmed the RTC decision, ruling the forfeiture clause improper. Reconsideration was denied on November 19, 2013. Petitioners then filed a petition for certiorari before the Supreme Court.
Issues:
- Core Issue
- Whether the Court of Appeals correctly affirmed the rescission of the Contract to Sell and ordered the return of amounts paid and remaining checks.
- Secondary Issue
- Whether petitioners—despite defaulting below—could obtain cancellation of the contract and forfeiture of respondents’ payments for respondents’ alleged payment defaults.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)