Case Digest (G.R. No. 61623)
Facts:
People's Homesite & Housing Corporation v. Court of Appeals, Rizalino L. Mendoza and Adelaida R. Mendoza, G.R. No. L-61623, December 26, 1984, the Supreme Court Second Division, Aquino, J., writing for the Court.The petitioner-appellant is People's Homesite & Housing Corporation (PHHC); the respondents-appellees are Rizalino L. Mendoza and Adelaida R. Mendoza. The dispute concerns whether PHHC became bound to sell a parcel identified as Lot 4 (Road) Pcs-4564 in Diliman, Quezon City (hereinafter Lot 4) to the Mendozas.
On February 18, 1960 the PHHC board adopted Resolution No. 513 awarding Lot 4, then shown as containing 4,182.2 square meters, to the Mendozas at P21.00 per square meter, expressly "subject to the approval of the Quezon City Council of the above-mentioned Consolidation Subdivision Plan" and to the approval of the PHHC Valuation Committee and higher authorities. The Quezon City Council disapproved that proposed consolidation subdivision plan on August 20, 1961, and the Mendozas were notified by registered mail.
A revised consolidation subdivision plan that again included Lot 4 but reduced its area to 2,608.7 (2,603.7) square meters was later prepared and was approved by the Quezon City Council on February 25, 1964. The Mendozas did not pay the agreed price nor make the 20% deposit initially required by PHHC; on April 26, 1965 the PHHC board passed a resolution recalling awards to persons who had failed to pay deposits.
On October 18, 1965 PHHC passed Resolution No. 218 withdrawing the tentative award of Lot 4 to the Mendozas and re-awarding Lot 4 jointly in equal shares to five other persons, subject to PHHC rules; those five paid the required 20% deposit, deeds of sale were executed in their favor, and the subdivision of Lot 4 into five lots received the necessary approvals, including from the city council and Bureau of Lands.
On March 16, 1966 the Mendozas sought reconsideration of the withdrawal and cancellation of the re-award, and then filed an action for specific performance and damages. The trial court sustained PHHC's withdrawal of the award. On appeal, the Court of Appeals reversed, declared...(Subscriber-Only)
Issues:
- Was there a perfected sale of Lot 4 to the Mendozas enforceable by an action for specific performance?
- If not, did PHHC act within its rights in withdrawing the tentative award and re-awarding Lot 4 to othe...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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