Case Digest (G.R. No. 26173)
Facts:
- The case Zacarias Robles vs. Lizarraga Hermanos was filed in the Court of First Instance of Occidental Negros.
- Zacarias Robles (plaintiff) sought compensation from Lizarraga Hermanos (defendant), a mercantile partnership.
- The dispute arose from improvements made by Robles on the hacienda "Nahalinan" and the value of farming equipment he supplied.
- The hacienda was originally owned by Zacarias Robles and his wife, Anastacia de la Rama.
- After the death of Zacarias Robles, Sr., Anastacia became the administratrix and leased the hacienda to their son, Zacarias Robles, for six years at an annual rent of P2,000.
- The lease stipulated that any permanent improvements would be at the lessee's expense without right to indemnity at the lease's end.
- Zacarias Robles made significant improvements and incurred substantial costs.
- Following Anastacia's death in 1916, her heirs sold the property to Lizarraga Hermanos.
- During negotiations, it was proposed that Zacarias surrender the last two years of his lease in exchange for compensation for improvements and purchase of personal property.
- The written contract executed on November 16, 1917, did not include these terms.
- Disputes arose regarding compensation, leading to the trial court ruling in favor of Zacarias Robles, awarding him P14,194.42.
- Lizarraga Hermanos appealed the decision.
Issue:
- (Unlock)
Ruling:
- The trial court did not err in admitting oral evidence of a contract different from the written contract of sale.
- The oral agreement regarding compensation for improvements and personal property was enforceable.
- The stipulation for appraisal did not create a suspensive condition that rendered the oral agreement ineffective.
- The defendant is obligated to indemnify the pla...(Unlock)
Ratio:
- The Supreme Court upheld the trial court's decision, stating that the oral agreement was independent of the written contract of sale.
- While written contracts typically supersede prior oral agreements, exceptions exist for collateral agreements that do not contradict written terms.
- Evidence, including ...continue reading
Case Digest (G.R. No. 26173)
Facts:
The case of Zacarias Robles vs. Lizarraga Hermanos was initiated in the Court of First Instance of Occidental Negros, where Zacarias Robles (plaintiff and appellee) sought compensation from Lizarraga Hermanos (defendant and appellant), a mercantile partnership. The action arose from improvements made by Robles on the hacienda "Nahalinan," located in Pontevedra, Occidental Negros, and the value of farming equipment supplied by him, alongside damages for breach of contract. The hacienda originally belonged to Zacarias Robles and his wife, Anastacia de la Rama. Following the death of Zacarias Robles, Sr., Anastacia was appointed administratrix of the estate and leased the hacienda to their son, Zacarias Robles, for six years starting from May 1915, with a stipulated annual rent of P2,000. The lease agreement specified that any permanent improvements made would be at the lessee's expense without right to indemnity at the lease's end.
To restore the hacienda, Zacarias Robles undertook significant improvements, including the installation of new equipment and construction of facilities, incurring substantial costs. In 1916, Anastacia passed away, and her heirs, including Zacarias Robles, later sold the property to Lizarraga Hermanos. During negotiations, it was proposed that Zacarias surrender the last two years of his lease, and in return, Lizarraga Hermanos would compensate him for the improvements and purchase his personal property on the hacienda. However, the written contract executed on November 16, 1917, did not explicitly include these terms. After the sale, disputes arose regarding the compensation for the improvements and the personal property, leading to the trial court ruling in favor of Zac...