Case Digest (G.R. No. 97442)
Facts:
- Pilar T. Ocampo is the petitioner, while the respondents are the Court of Appeals and Magdalena S. Villaruz.
- The case involves an 18,260-square meter lot in Tigbauan, Iloilo, originally owned by Severino Tolosa, registered under Original Certificate of Title No. 0-7743.
- On August 20, 1974, Tolosa mortgaged the property to the Philippine Veterans Bank, which was noted on his title.
- On March 17, 1975, Tolosa entered into a contract with Ocampo, represented by Teresa T. Borres, to sell the property for P22,000, with an initial payment of P1,000.
- An Agreement to Sell Real Property was executed on April 21, 1975, for P25,000, with a down payment of P12,500 and the balance due within six months.
- Ocampo paid a total of P16,700 before the deadline and later made late payments totaling P3,900.
- Ocampo filed an adverse claim on June 6, 1976, upon discovering the mortgage lien.
- Tolosa attempted to cancel the adverse claim, offering Ocampo a refund or a share of proceeds from a potential sale.
- On June 3, 1977, Tolosa entered into a Contract to Sell with Villaruz for P94,300, with a down payment of P15,000, contingent on the cancellation of all liens.
- The Regional Trial Court ruled in favor of Ocampo on January 7, 1988, declaring the contract with Villaruz null and void.
- The Court of Appeals reversed this decision on October 11, 1990, declaring Villaruz the absolute owner of the property.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Agreement to Sell between Tolosa and Ocampo was a valid contract of sale.
- The Court held that Tolosa did not have the right to sell the property to Villaruz, as Ocampo had a better title.
- The Supreme Court reversed the Court of Appeals'...(Unlock)
Ratio:
- The Supreme Court determined that the Agreement to Sell constituted a perfected contract of sale, indicating an intent to transfer ownership upon payment.
- The absence of a deed of absolute sale did not negate ownership transfer, as the contract's terms did not reserve ownership for Tolosa until full payment.
- The Court emphasized that a contract is considered absolute unless explicitly stated otherwise, and failure to pay the full price within the stipulated time does not automatically void the contract.
- Ocampo&#...continue reading
Case Digest (G.R. No. 97442)
Facts:
The case involves Pilar T. Ocampo as the petitioner and the Court of Appeals and Magdalena S. Villaruz as respondents. The dispute centers around an 18,260-square meter lot located in the Poblacion of Tigbauan, Iloilo, which was originally owned by Severino Tolosa, who had registered the property under Original Certificate of Title No. 0-7743. On August 20, 1974, Tolosa mortgaged the property to the Philippine Veterans Bank, which was annotated on his title. On March 17, 1975, Tolosa entered into a contract with Ocampo, represented by Teresa T. Borres, to sell the property for P22,000, with an initial payment of P1,000. Subsequently, on April 21, 1975, they executed an Agreement to Sell Real Property for P25,000, with a down payment of P12,500 and the balance due within six months. Ocampo, however, only managed to pay a total of P16,700 before the deadline, but Tolosa accepted late payments totaling P3,900.
In the meantime, Ocampo learned of the mortgage lien and filed an adverse claim on June 6, 1976. Tolosa later sought to cancel this claim, offering Ocampo a refund or a share of the proceeds if the property was sold to a third party. On June 3, 1977, Tolosa entered into a Contract to Sell with Villaruz for P94,300, with a down payment of P15,000 and the balance contingent upon the cancellation of all liens. The contract also stipulated that possession would be conveyed to Villaruz immediately, although a deed of sale would only be delivered upon full payment.
Tolosa's attempts to cancel Ocampo's adverse claim were unsuccessful, and he subsequently filed a petition to cancel it. On January 7, 1988, the Regional Trial Court of Iloilo ruled in favor of Ocampo, declaring the contract with Villaruz null and void ...