Case Digest (G.R. No. 94563)
Facts:
Meynardo C. Policarpio and Lourdes Policarpio v. Honorable Court of Appeals, Evelyn Q. Catabas, Romulo Q. Catabas, and Clemente Catabas, G.R. No. 94563, March 05, 1991, Supreme Court Third Division, Gutierrez, Jr., J., writing for the Court.On November 25, 1983 the petitioners-spouses, Meynardo C. Policarpio and Lourdes Policarpio (vendors), and private respondents Evelyn, Romulo and Clemente Catabas (vendees) executed a Contract to Sell covering a residential lot (TCT No. 501812) in UE Village, Cainta, Rizal for P270,000, with P10,000 down and the P260,000 balance to be paid from a PAG-IBIG loan through Urban Bank on or before the first week of December 1983. The contract provided that failure by the vendees to pay by that deadline would automatically annul the contract and require return of the downpayment.
The vendees did not pay the balance by the deadline but continued making partial payments totaling P75,000. On April 9, 1984 the parties executed a Deed of Absolute Sale (stating an undervalued consideration of P230,000) and the vendees were given physical possession. The parties disagreed over whether the deed reflected an actual sale or a simulated document to facilitate the vendees' loan; the vendors asserted an oral agreement to increase the price to P330,000 and other contingent understandings.
On March 1, 1985 the vendees filed suit in the Regional Trial Court (RTC) of Pasig for specific performance and damages, alleging the vendors refused to deliver title and to cooperate with the loan takeout. The petitioners counterclaimed. The RTC found for the petitioners, dismissed the complaint, declared the Contract to Sell and the simulated Deed of Absolute Sale void insofar as they purported to effect a transfer, awarded possession rents and several damages items including moral, exemplary and attorneys’ fees.
The Court of Appeals reversed the RTC in an April 30, 1990 decision (CA-G.R. Civil Case No. 16069), ordering among others that the respondents authorize Urban Bank/PCIB releases and transfer title to the vendees and that the vend...(Pro-only)
Issues:
- Did the Court of Appeals err in reversing the RTC’s factual findings and judgment?
- Were the private respondents entitled to specific performance (transfer of title) under the facts?
- Were the awards of moral damages, exemplary damages, and attorneys’ fees to the petitioners proper...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)