Title
Olivarez Realty Corp. vs. Castillo
Case
G.R. No. 196251
Decision Date
Jul 9, 2014
Benjamin Castillo sued Olivarez Realty for breaching a conditional sale contract over disputed land; SC upheld cancellation, forfeited payments, and awarded damages.

Case Digest (G.R. No. 196251)
Expanded Legal Reasoning Model

Facts:

  • Ownership and Title Dispute
    • Benjamin Castillo owned a 346,918-sqm parcel in Laurel, Batangas (TCT No. T-19972); the Philippine Tourism Authority claimed the same land under TCT No. T-18493.
    • On April 5, 2000, Castillo and Olivarez Realty Corporation (represented by Dr. Pablo R. Olivarez) entered into a deed of conditional sale for ₱19,080,490.00.
  • Contractual Terms
    • Down payment of ₱5,000,000.00 in scheduled installments between April and November 2000; balance of ₱14,080,490.00 to be paid in 30 equal monthly installments upon voiding of the PTA title.
    • Olivarez Realty Corporation to file suit against PTA and pay disturbance compensation to tenants; Castillo to assist and to clear tenants within six months; immediate possession granted to the corporation; improvements forfeited upon cancellation.
  • Alleged Defaults and Court Proceedings
    • The corporation paid only ₱2,500,000.00, did not file suit against PTA, nor clear tenants or pay disturbance compensation; Castillo filed for rescission under Art. 1191, alleging breach and contract of adhesion, and sought moral, exemplary damages, attorney’s fees, and costs.
    • Defendants counterclaimed for litigation expenses; Castillo moved for summary judgment; the RTC granted rescission, forfeited ₱2,500,000.00 in Castillo’s favor, and awarded moral (₱500,000.00), exemplary (₱50,000.00) damages, and costs of suit.
  • Appellate and Supreme Court Proceedings
    • The Court of Appeals affirmed the RTC decision in toto on July 20, 2010; denied reconsideration on March 18, 2011.
    • Olivarez Realty Corporation and Dr. Olivarez filed a petition for review on certiorari with the Supreme Court, contesting summary judgment, damages awards, and docket fees.

Issues:

  • Whether the trial court erred in rendering summary judgment.
  • Whether correct docket fees were paid, thereby conferring jurisdiction on the RTC.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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