Case Digest (G.R. No. 164587)
Facts:
Rockland Construction Company, Inc. v. Mid-Pasig Land Development Corporation, G.R. No. 164587, February 04, 2008, Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Rockland Construction Company, Inc. sought specific performance against respondent Mid-Pasig Land Development Corporation, asking the Regional Trial Court (RTC), Branch 67, Pasig City, to compel Mid-Pasig to execute a lease over a 3.1-hectare parcel that is covered by titles under the control of the Presidential Commission on Good Government (PCGG).
Chronologically, Rockland first sent an offer to lease Mid-Pasig’s property by letter dated March 1, 2000 and, at Mid-Pasig’s direction, addressed the PCGG on April 15, 2000 with proposed terms. On June 8, 2000 Rockland sent Mid-Pasig a follow-up letter enclosing a Metropolitan Bank and Trust Company check for P1,000,000 as a sign of good faith; Mid-Pasig received that letter on July 28, 2000. Rockland later wrote on February 2, 2001 claiming it presumed acceptance because the P1,000,000 check had been credited to Mid-Pasig’s account on December 5, 2000. Mid-Pasig denied knowledge of any such deposit and, upon learning of the claimed deposit only after receipt of Rockland’s February 2 letter, investigated and wrote Rockland on February 6 and February 13, 2001 rejecting the lease application and refusing to entertain Rockland’s offer.
Rockland filed Civil Case No. 68350 for specific performance in the RTC to compel execution of the lease. On September 2, 2002 the trial court ruled for Rockland, declaring that the parties had agreed to a valid lease covering 31,000 square meters (areas A, B and C), adopting the principal terms stated in Rockland’s June 8, 2000 letter, ordering Mid-Pasig to execute a written lease within 60 days, to maintain Rockland in peaceful possession, awarding attorney’s fees, and making a prior TRO permanent. Mid-Pasig’s counterclaim was dismissed.
On appeal, the Court of Appeals, in a Decision dated February 27, 2004 (and a subsequent Resolution of July 21, 2004), reversed and set aside the RTC judgment, dismissed Rockland’s complaint and Mid-Pasig’s counterclaim, and held that there was no perfected contract of lease because: (1) there was no meeting of the minds; (2) Mid-Pasig did not impliedly accept the P1,000,000 check because it was unaware of its source when it first learned of the deposit; and (3) Rockland’s subsequent conduct (failure to take possession and failure to pay rent) contradicted its claim of an existing lease. Rockland’s motion for reconsideration before the Court of Appeals was denied.
Petitioner brought the case to the Co...(Pro-only)
Issues:
- Was there a perfected contract of lease between Rockland and Mid-Pasig?
- Did estoppel in pais arise from Mid-Pasig’s depositing/collecting the P1,000,000 check, thereby precluding Mid-Pasig from de...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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