Case Digest (G.R. No. 192565)
Facts:
In Jaime G. Ong vs. Court of Appeals and Spouses Miguel K. Robles and Alejandra M. Robles (G.R. No. 97347, July 6, 1999), petitioner Jaime G. Ong and respondents Miguel and Alejandra Robles executed on May 10, 1983 an Agreement of Purchase and Sale covering two parcels of agricultural land, a rice mill, piggery, and residential improvements in Barrio Puri, San Antonio, Quezon, for a total price of ₱2,000,000. Under the contract’s terms, Ong paid an initial ₱103,499.91 and agreed to deposit ₱496,500.09 directly with the Bank of the Philippine Islands (BPI) to answer for the spouses’ existing BPI loan, while the remaining ₱1,400,000 was to be paid in four quarterly installments of ₱350,000 each. Ong took possession on May 15, 1983, deposited only ₱393,679.60 toward the BPI loan, issued four post-dated Metrobank checks which were later dishonored, and failed to replace them. Facing foreclosure, the spouses sold three rice-mill transformers with Ong’s written authorization, promisin...
Case Digest (G.R. No. 192565)
Facts:
- Agreement of Purchase and Sale
- May 10, 1983: Petitioner Jaime G. Ong and respondents Spouses Miguel K. Robles and Alejandra M. Robles executed a contract covering two parcels of land in Barrio Puri, San Antonio, Quezon for ₱2,000,000.
- Payment terms:
- Initial ₱600,000 broken into:
- Balance of ₱1,400,000 in four equal quarterly installments of ₱350,000, due June 15, Sept 15, Dec 15 1983 and March 15 1984.
- Sellers’ obligations: deliver deed of sale and clear title upon full payment and surrender possession immediately.
- Performance and Breach
- Buyer took possession May 15, 1983, and deposited the ₱103,499.91; paid only ₱393,679.60 of the ₱496,500.09 BPI loan.
- Issued four post-dated checks of ₱350,000 each, all dishonored for insufficient funds.
- Bank threatened foreclosure; Sellers sold three rice-mill transformers (₱51,411) with Buyer’s consent; Sellers operated rice mill; Buyer remained in possession of land.
- August 2, 1985: Sellers’ demand for return of properties; unheeded.
- September 2, 1985: Sellers filed complaint for rescission and recovery of properties with damages in RTC Lucena.
- Trial court issued preliminary injunction: Buyer enjoined from making improvements except repairs.
- June 1, 1989: RTC rendered judgment:
- Set aside the contract;
- Ordered Buyer to return land and improvements;
- Ordered Sellers to refund ₱497,179.51;
- Awarded Sellers ₱100,000 exemplary damages;
- Awarded Sellers ₱20,000 attorney’s fees.
- CA affirmed RTC decision but deleted exemplary damages.
- Petitioner elevated case to the Supreme Court.
Issues:
- Whether the contract may be validly rescinded under Article 1191 of the New Civil Code.
- Whether the original contract as to time and manner of payment was novated by subsequent acts or agreements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)