Case Digest (G.R. No. 133208)
Facts:
Ramel v. Aquino, G.R. No. 133208, July 31, 2006, Supreme Court Second Division, Puno, J., writing for the Court.Petitioners Laurencio C. Ramel, Socorro B. Ramel and Rene Lemar B. Ramel sued respondents Daniel Aquino (owner of TCT No. T-36937) and Guadalupe Abalahin for specific performance with preliminary injunction and damages; Benjamin Aquino and Virginia Aquino intervened as co-owners of the contested land. The dispute arose from an oral sale in August 1983 by which respondents offered to sell petitioners an 8.2030-hectare southern portion of Lot No. 2080 (a 14.1825-hectare parcel) to avert foreclosure of a DBP mortgage; petitioners agreed to assume the outstanding mortgage (about P85,544.92 as of July 31, 1983) and to pay the balance (about P25,000.00) to respondents.
Petitioners paid earnest and subsequent sums to respondents (P5,000 on Aug. 7, 1983; P15,000 on Sept. 7, 1983; P4,800 on Feb. 12, 1984) and bought an additional 2,484 sqm for P2,700 (Sept. 7, 1983). They also made partial payments to DBP (P10,000 on Sept. 7, 1983; P3,097 on Nov. 18, 1983; P10,000 on Apr. 2, 1984 — total P23,097) and obtained bank approval to restructure the mortgage into a ten‑year schedule in November 1983. Respondents later alleged they had not consented to restructuring, claimed a different purchase price arrangement (P35,000 balance), and, upon learning of the restructuring, tendered P72,703.06 to DBP on Oct. 1, 1984 and declared the sale rescinded.
Petitioners filed their complaint for specific performance on Oct. 9, 1984; the trial court issued a temporary restraining order on Oct. 12, 1984 enjoining respondents and DBP from releasing the title. During litigation petitioners later paid DBP in full (P30,000 on Nov. 29, 1984; P50,000 on Apr. 30, 1986; P5,118.42 on May 2, 1986 — total ≈ P108,216), and DBP deposited the Release of Mortgage with the Clerk of Court. The Regional Trial Court (Branch 21, Santiago, Isabela) rendered judgment on June 28, 1990: it declared the oral sale rescinded, ordered respondents to execute a deed of sale for the 2,484 sqm to Rene Ramel, and directed respondents to pay petitioners P29,800 (amount received) plus P108,216 (payments to DBP), with intervenors ordered to reimburse their one‑third shares.
The Court of Appeals in CA‑G.R. CV No. 28654 affirmed the trial court’s decision (Apr. 16, 1997) and denied reconsideration (Mar. 25, 1998). Petitioners elevated the case to the Supreme Court by Petition for Review on Certiorari under Rule 45, attacki...(Pro-only)
Issues:
- Did respondents satisfy the demand requirement of Article 1592, Civil Code, so as to validly seek rescission?
- Did petitioners commit a substantial breach of their obligation warranting rescission under Article 1191, Civil Code?
- Was the trial court’s offsetting of petitioners’ claimed improvements against respondents’ claim...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)