Case Digest (G.R. No. L-39822)
Facts:
Antonio E. Prats, doing business under the name of Philippine Real Estate Exchange v. Hon. Court of Appeals, Alfonso Doronila and Philippine National Bank, G.R. No. L-39822, January 31, 1978, the Supreme Court First Division, Fernandez, J., writing for the Court.Petitioner Antonio E. Prats (doing business as Philippine Real Estate Exchange) filed Civil Case No. Q-12412 in the Court of First Instance of Rizal at Quezon City on September 23, 1968 against respondent Alfonso Doronila and Philippine National Bank (PNB) to recover a broker's commission and damages. Prats alleged that on February 14, 1968 Doronila gave him an exclusive written option to negotiate the sale of 300 hectares in Montalban, Rizal at P3.00 per square meter, with a 10% commission based on P2.10 per square meter and specific provisions for extension and required written offers.
The complaint and a January 18, 1969 stipulation of facts recount a sequence of negotiations with the Social Security System (SSS): earlier offers by Doronila to SSS in 1967; Prats' February 1968 exclusive authority and follow-up communications (including publication and letters to SSS and the Presidential Housing Commission); Prats' written offers on behalf of a buyer (including offers of P6.00 on May 6, 1968 and P4.50 on May 18, 1968); SSS activity including a June 20, 1968 Resolution (No. 636) formalizing a counter-offer of P3.25 per square meter, an appraisal, and a July 17, 1968 favorable action; and ultimately the deed of sale executed by Doronila in favor of SSS on July 30, 1968 for P9,750,000.00 (P3.25/sq.m.), with registration on August 21, 1968 and full payment deposited in Doronila’s PNB account.
Prats demanded payment of his professional fee (P1,380,000.00) on September 17, 1968; Doronila refused and countered that Prats’ exclusive authority had expired and that Doronila had earlier negotiated directly with SSS. The trial court, by decision dated December 12, 1969, found for Prats: it awarded P1,380,000.00 with interest, moral and exemplary damages, attorney’s fees (P150,000.00), and made permanent a preliminary injunction entailing PNB to pay from a P2,000,000.00 fixed deposit.
Doronila appealed to the Court of Appeals (CA-G.R. No. 45974-R). In a decision promulgated September 19, 1974 the Court of Appeals reversed and dismissed the complaint, holding that Prats’ exclusive authority had expired (the CA found no written offer by SSS within the option period and that Prats was not the efficient procuring cause), awarded Doronila P10,000.00 for attorney’s fees, and lifted the injunction on the P2,000,000.00 deposit. Prats filed a petition for certiorari to the Supreme Court; the Court initially denied the petition on May 23, 1975 but, on motion for reconsideration and supplemental petition invoking equity, gave the petition due course by Resolution of August 20, 1975.
The Supreme Court considered the stipulation of facts and record testimony and accepted the Court of Appeals’ factual findings that the SSS’s formal acceptance occurred after Prats’ exclusive authority had expired. Whi...(Pro-only)
Issues:
- Was petitioner Prats the efficient procuring cause of the sale such that he is entitled to the agreed commission?
- Did petitioner comply with the terms of the exclusive option (including the written-offer requirement and timing) so as to preserve his contractual right to commission?
- Was the Court of Appeals' award of attorney’s fees to Doronila and denial of Prats’ damages/fees erroneous, or should Prats receive some relief in equit...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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