Case Digest (G.R. No. 173622) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Robern Development Corporation v. People’s Landless Association, the petitioners Robern Development Corporation and its president Rodolfo M. Bernardo, Jr. sought review of the Court of Appeals’ August 16, 2005 Decision and May 30, 2006 Resolution ordering reconveyance of a 2,000-square meter lot in Magtu-od, Davao City, originally covered by TCT No. 138914, from Robern back to respondent People’s Landless Association (PELA). The land was owned by Al-Amanah Islamic Development Bank of the Philippines, which in March 1993 received P150,000 as a partial deposit from PELA upon its offer to buy the property for P300,000. The bank’s Davao Branch acknowledged receipt of the deposit but made clear that acceptance was “subject to approval” by its Head Office. After several months, Al-Amanah formally rejected PELA’s offer for being below its P1,000,000 asking price, demanded that PELA vacate, and subsequently sold the lot to Robern in early 1994 for P400,000. PELA thereupon filed an ac... Case Digest (G.R. No. 173622) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Al-Amanah Islamic Development Bank (Al-Amanah) owned a 2,000-square-meter lot in Magtu-od, Davao City, covered by TCT No. 138914.
- People’s Landless Association (PELA) members, informal settlers on the lot, were asked (Dec. 12, 1992) to vacate or buy at P100/sqm; bank rejected the price and reiterated eviction demands.
- PELA’s Offer and Deposits
- March 18, 1993: PELA offered to buy the lot for P300,000 (P150,000 down, balance in one year); bank annotated “offer acknowledged/received but processing to take effect upon putting up of the partial amt. of P150,000 on or before April 15, 1993.”
- By May 3, 1993, PELA deposited P150,000 via four receipts labeled “partial deposit on sale of TCT No. 138914”; meanwhile, PELA members improved the property.
- Rejection of PELA’s Offer and Letters to Vacate
- Nov. 29, 1993 and Dec. 14, 1993: Al-Amanah’s Head Office formally rejected the P300,000 offer (citing P500/sqm bank price), demanded PELA vacate and remove structures within 15 days, and offered to refund P150,000.
- Robern’s Purchase Transaction
- Dec. 27, 1993: Robern Development Corporation (Robern) offered P400,000 (20% deposit, cash basis, will shoulder relocation); Al-Amanah Board accepted.
- Robern paid P80,000 deposit; informed to eject occupants and pay P320,000 balance by Feb. 9, 1994; balance paid Mar. 4, 1994; Deed of Sale executed Apr. 6, 1994; TCT No. 212983 issued in Robern’s name.
- PELA’s Court Proceedings
- Apr. 1994: PELA consigned P150,000 in RTC and wrote Al-Amanah to process documents, claiming full payment.
- July 14, 1994: PELA filed suit for Annulment and Cancellation of Void Deed of Sale against Al-Amanah, Robern, and officers; secured TRO and preliminary injunction from RTC (Nov. 9, 1994), affirmed by CA in SP No. 35238.
- Decisions Below
- RTC (Aug. 10, 1999): Dismissed PELA’s complaint—no perfected sale with PELA (offer only, no acceptance, OIC lacked board authority), valid sale to Robern.
- CA (Aug. 16, 2005; reso. May 30, 2006): Reversed RTC—found perfected contract with PELA, invalidated Robern sale, ordered reconveyance and damages; denied motions for reconsideration.
Issues:
- Was there a perfected contract of sale between PELA and Al-Amanah?
- If not, should the sale of the lot to Robern be upheld as valid?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)