Case Digest (G.R. No. 112733)
Facts:
- People's Industrial and Commercial Corporation (petitioner) entered into agreements with Mar-ick Investment Corporation (private respondent) to purchase six lots in Mar-ick Subdivision, Cainta, Rizal, on May 29, 1961.
- The petitioner paid the down payment and eight installments but failed to complete the payments over ten years.
- The agreements stipulated automatic cancellation without notice if payments were not completed within 120 days from the due date. The private respondent canceled the contracts accordingly.
- After negotiations, an unsigned draft contract to sell seven lots was created on October 11, 1983.
- The petitioner issued five checks amounting to P37,642.72, which the private respondent received but did not encash.
- The private respondent filed a complaint for accion publiciana de posesion.
- The Regional Trial Court validated the cancellation of the original agreements and ordered the petitioner to pay rentals and attorney's fees.
- The Court of Appeals affirmed the lower court's decision.
- The petitioner sought review by the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the issue of jurisdiction was precluded by estoppel due to the petitioner's active participation in the proceedings.
- The Court found that the new contract to sell was not perfected and enforceable.
- The Court did not find it necessary to discuss the is...(Unlock)
Ratio:
Jurisdiction and Estoppel:
- The petitioner was estopped from questioning jurisdiction due to its active participation in proceedings without initially raising the issue.
- The legal bases cited by the petitioner were not applicable as they did not exist when the contracts were canceled in 1971.
Perfection of the New Contract:
- The draft contract in 1983 was not signed, and there was no meeting of the minds on essential terms.
- The checks issued by the petitioner were not encashed, and no further performance or payment occurred, so the new contract ...continue reading
Case Digest (G.R. No. 112733)
Facts:
The case involves People's Industrial and Commercial Corporation (petitioner) and Mar-ick Investment Corporation (private respondent), the registered owner of Mar-ick Subdivision in Barrio Buli, Cainta, Rizal. On May 29, 1961, the private respondent entered into six agreements to sell six subdivision lots to the petitioner. The petitioner paid the down payment and eight installments but failed to complete the payments over ten years. As stipulated in the agreements, failure to pay within 120 days from the due date would result in automatic cancellation without notice. Consequently, the private respondent canceled the contracts. After negotiations, the parties drafted a new contract to sell seven lots on October 11, 1983, but it was never signed. The petitioner issued five checks totaling P37,642.72, which the private respondent received but did not encash. The private respondent then filed a complaint for accion publiciana de posesion against the petitioner and its president, Tomas Siatianum. The Regional Trial Court ruled that the original agreements were validly canceled and ordered the petitioner to pay rentals and attorney's fees. The Court of Appeals affirmed this decision, leading the petitioner to file for review with the Supreme Court.
Issue:
- Did the lower court have jurisdiction over the subject matter in light of Republic Act No. 6552 and Presidential Decree No. 1344?
- Was there a perfected and enforceable contract to sell on October 11, 1983?
- Was there a valid grant of right of way i...