Case Digest (G.R. No. 107372) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 30, 1982, private respondents Oscar and Asuncion Llanes Inocentes sold two titled parcels in Quezon City to petitioner Rafael S. Ortanez for ₱35,000.00 (TCT No. 258628) and ₱20,000.00 (TCT No. 243273). Both instruments were denominated as deeds of absolute sale, acknowledged full payment, and named Ortanez, a Filipino under complete separation of property, as buyer. Although respondents received the agreed sums, they failed to deliver the certificates of title. On April 9, 1990, Ortanez formally demanded their release. Respondents refused, asserting that the title to the first lot was with another person for subdivision, and that delivery of the second was contingent upon compliance with four alleged oral conditions—segregating a 398 sq. m. right-of-way, submitting the approved segregation plan, erecting a dividing wall, and paying capital gains tax and incidental expenses. These stipulations did not appear in the written deeds. Ortanez filed for specific performanc Case Digest (G.R. No. 107372) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Sale Transactions
- On September 30, 1982, private respondents Oscar and Asuncion Inocentes sold two parcels of registered land in Quezon City to petitioner Rafael S. Ortañez for ₱35,000 (Lot 684-G-1-B-2, TCT No. 258628) and ₱20,000 (Lot 5, TCT No. 243273).
- Both deeds of absolute sale recited full payment and described the transfers as unconditional and “absolute,” naming petitioner (married under complete separation of property) and his heirs or assigns as grantee.
- Non-Delivery and Oral Conditions
- Although payment was made, respondents failed to deliver the titles. On April 9, 1990, petitioner formally demanded delivery of the TCTs.
- Respondents refused, alleging the first title was with a third party for subdivision and the second was subject to four oral conditions never reduced to writing:
- Segregation of a 398-sq. m. right of way;
- Submission of an approved plan for segregation;
- Construction of a dividing wall;
- Payment of capital gains tax and related expenses.
- Petitioner sued for specific performance; respondents counterclaimed but admitted the oral conditions only through the testimony of Oscar Inocentes.
- The trial court, over petitioner’s parol-evidence objections, admitted the oral conditions and dismissed both the complaint and the counterclaim. The Court of Appeals affirmed that decision.
Issues:
- Whether parol evidence is admissible to establish alleged oral conditions precedent to a contract of sale when the written deeds of absolute sale are silent on such conditions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)