Case Digest (G.R. No. 214115) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Province of Cebu v. Spouses Victor and Catalina Galvez, G.R. No. 214115, decided on February 15, 2023 under the 1987 Constitution, the Spouses Galvez (respondents) sought specific performance and damages against the Province of Cebu (petitioner) over two parcels of land in Fuente Osmeña and Lahug, Cebu City. In 1964, the Provincial Board donated 210 parcels to the City of Cebu. The city held public auctions in June and August 1965, at which respondents successfully bid for a 300-sqm portion of Lot No. 526-B for ₱24,300 and for Lot No. 1072 for ₱78,893.84. Contracts of Purchase and Sale dated August 11 and 12, 1965 were executed, with down payments and installment terms over three years. On August 6, 1965, Governor Rene Espina secured a writ of preliminary injunction enjoining conveyance of the donated realties, prompting the City to suspend closing and retain respondents’ deposits. In 1974, petitioner and the City compromised, returning undeveloped lots to petitioner and remi Case Digest (G.R. No. 214115) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Donation and Auction
- On February 4, 1964, the Provincial Board of Cebu issued Resolution No. 168 donating 210 parcels of land (including Lot 526-B in Fuente Osmeña and Lot 1072 in Lahug) to the City of Cebu, which the City accepted and pursuant to Ordinance No. 522 authorized their sale by public auction.
- The City conducted three public biddings on June 26, July 19, and August 5, 1965.
- Contracts with Respondents
- On June 26, 1965, respondents were awarded a 300-sqm portion of Lot 526-B at PHP 24,300.00 (down payment PHP 4,860.00; balance PHP 19,440.00 in three years). A Contract of Purchase and Sale was executed on August 12, 1965.
- On August 5, 1965, respondents were awarded Lot 1072 at PHP 78,893.84 (down payment PHP 15,778.77; balance PHP 63,115.07 in three years). A Contract of Purchase and Sale was executed on August 11, 1965.
- Nullification Suit and Injunction
- On August 6, 1965, then-Governor René Espina filed Civil Case No. 238-BC seeking nullification of the provincial donation; the Court of First Instance issued a preliminary injunction the same day enjoining conveyance of the donated realties.
- The injunction was served on the City of Cebu on August 9–10, 1965.
- Compromise Agreement
- On June 25, 1974, petitioner and the City of Cebu entered into a compromise agreement (approved July 15, 1974) returning most donated lands to petitioner, with petitioner bearing liability for sales to third parties.
- The City remitted to petitioner PHP 187,948.93 representing buyers’ deposits, including those of respondents.
- Respondents’ Payment and Suit for Specific Performance
- Respondents attempted to pay the balance of the purchase price but were refused due to the injunction; on August 1, 1994, they paid the remaining balance, which Governor Pablo P. Garcia confirmed in a July 12, 2001 letter.
- On July 25, 1994, respondents filed an action for Specific Performance with Damages against petitioner for failing to execute the deeds of sale.
- Intervention and Trial Court Decision
- July 26, 1994: respondents filed a notice of lis pendens; April 25, 1996: Philippine Veterans Bank (PVB) intervened and subsequently acquired Lot 2-B-2 in a 1996 public bidding.
- March 31, 2009 RTC Decision declared respondents co-owners of the subject lots, ordered petitioner to execute deeds of sale, PVB to pay fair market value, and both parties to pay damages and attorney’s fees.
- CA Decision and Motion for Reconsideration
- April 14, 2014: Court of Appeals affirmed the RTC decision in toto.
- August 12, 2014: CA denied petitioner’s motion for reconsideration.
Issues:
- Validity of Contracts
- Whether valid contracts of sale existed despite service of the preliminary injunction before formal execution of the deeds of sale.
- Payment of Purchase Price
- Whether respondents fully paid the purchase price absent formal proof of valid tender and consignation.
- Laches
- Whether respondents’ nearly 29-year delay barred their claim by laches.
- Moral and Exemplary Damages
- Whether the award of moral and exemplary damages to respondents was proper.
- Attorney’s Fees
- Whether ordering petitioner to reimburse respondents’ contingent attorney’s fees (35%) was erroneous.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)