Facts:

The case involves the People's Homesite and Housing Corporation (PHHC) as the petitioner-appellant and Rizalino L. Mendoza and Adelaida R. Mendoza as the respondents-appellees. The events leading to the case began on February 18, 1960, when the PHHC's board of directors passed Resolution No. 513, which awarded Lot 4 (Road) Pcs-4564, located in Diliman, Quezon City, to the Mendoza spouses at a price of P21.00 per square meter, contingent upon the approval of the Quezon City Council and the PHHC Valuation Committee. However, on August 20, 1961, the city council disapproved the proposed consolidation subdivision plan, and the Mendozas were notified of this disapproval via registered mail. Subsequently, a revised subdivision plan was submitted and approved by the city council on February 25, 1964, which included Lot 4 but with a reduced area of 2,608.7 square meters.

Despite the approval of the revised plan, the Mendozas did not pay the required deposit or the purchase...

Facts:

1. Award of Lot 4 to the Mendozas

   • On February 18, 1960, the People's Homesite and Housing Corporation (PHHC) Board of Directors passed Resolution No. 513, awarding Lot 4 (with an area of 4,182.2 square meters) to spouses Rizalino and Adelaida Mendoza at a price of P21.00 per square meter.
   • The award was subject to the approval of the Quezon City Council for the consolidation subdivision plan and the PHHC Valuation Committee and higher authorities.

2. Disapproval of the Subdivision Plan

   • On August 20, 1961, the Quezon City Council disapproved the proposed consolidation subdivision plan. The Mendozas were notified of this disapproval via registered mail.

3. Revised Subdivision Plan

   • A revised subdivision plan was prepared, reducing the area of Lot 4 to 2,608.7 square meters. This revised plan was approved by the Quezon City Council on February 25, 1964.

4. Failure to Pay and Withdrawal of Award

   • The Mendozas never paid the price of the lot or made the required 20% initial deposit.
   • On April 26, 1965, the PHHC Board passed a resolution recalling all awards to individuals who failed to pay the deposit or down payment.
   • On October 18, 1965, the PHHC Board passed Resolution No. 218, withdrawing the tentative award of Lot 4 to the Mendozas and re-awarding it to five other individuals.

5. Legal Action by the Mendozas

   • On March 16, 1966, the Mendozas requested reconsideration of the withdrawal of the award and cancellation of the re-award.
   • Before their request could be acted upon, they filed an action for specific performance and damages.

6. Lower Court Decisions

   • The trial court upheld the withdrawal of the award.
   • The Court of Appeals reversed the trial court's decision, declaring the re-award and deeds of sale void and ordering the PHHC to sell Lot 4 to the Mendozas at P21 per square meter, plus P4,000 in attorney's fees and litigation expenses.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Conditional Award

   • The award of Lot 4 to the Mendozas was conditional, contingent upon the approval of the Quezon City Council for the subdivision plan and the PHHC Valuation Committee and higher authorities.
   • Since the city council initially disapproved the plan, the condition was not met, and the award remained tentative.

2. No Meeting of Minds

   • Under Article 1475 of the Civil Code, a contract of sale is perfected only when there is a meeting of minds on the object and price.
   • In this case, there was no meeting of minds because the Mendozas failed to manifest their acceptance of the reduced area of Lot 4 after the revised plan was approved in 1964.

3. Withdrawal of Award

   • The PHHC acted within its rights in withdrawing the tentative award since the Mendozas failed to pay the required deposit or down payment.
   • The withdrawal was consistent with the conditional nature of the award.

4. Distinction from Lapinig vs. Court of Appeals

   • The case of Lapinig vs. Court of Appeals is not applicable because, in that case, the awardee had paid the deposit and a conditional contract to sell was executed.

5. Legal Principles

   • The Court cited Article 1181 of the Civil Code, which states that in conditional obligations, the acquisition of rights depends on the happening of the event constituting the condition.
   • The condition in this case (approval of the subdivision plan) was not fulfilled, and thus, no perfected sale occurred.

Conclusion:

The Supreme Court ruled that there was no perfected sale of Lot 4 to the Mendozas. The PHHC's withdrawal of the tentative award was valid, and the Mendozas could not enforce the sale through specific performance.