Case Digest (G.R. No. 174118)
Facts:
The Roman Catholic Church, represented by the Archbishop of Caceres, v. Regino Pante, G.R. No. 174118, April 11, 2012, Supreme Court Second Division, Brion, J., writing for the Court. The petition for review on certiorari under Rule 45 seeks to set aside the Court of Appeals' May 18, 2006 decision and its August 11, 2006 resolution in CA-G.R.-CV No. 65069, which reversed the Regional Trial Court of Naga City, Branch 24's July 30, 1999 judgment.The parties are the Roman Catholic Church (petitioner), acting through the Archbishop of Caceres, and Regino Pante (respondent); the spouses Nestor and Fidela Rubi figured as defendants in the RTC proceedings and claimants of the subsequent sale. On September 25, 1992 the Church executed a contract to sell a 32-square meter strip (2x16 m) in Barangay Dinaga, Canaman, Camarines Sur to Pante for P11,200, with P1,120 downpayment and the balance payable within three years. On June 28, 1994 the Church sold a 215-square meter lot that included the 32-square meter strip to the spouses Rubi; the Rubis later erected a concrete fence that blocked Pante’s access.
When parties failed to settle, Pante filed with the RTC an action to annul the Church’s sale to the Rubis insofar as it included the strip sold to him. The Church answered and counterclaimed to annul its contract with Pante, alleging that consent was vitiated by fraud because Pante had misrepresented himself as an actual occupant, contrary to the Church’s asserted policy of selling only to occupants. During pretrial the parties admitted four facts, including that the lot was a 2x16 strip, that the Church had sold it to Pante on September 25, 1992, that the Church later included it in the sale to the Rubis, and that Pante had represented himself as being an actual occupant.
In a July 30, 1999 decision the RTC annulled the contract between the Church and Pante under Article 1390 of the Civil Code for vitiated consent, ordered return of Pante’s downpayment with interest, and upheld the sale to the Rubis; the RTC also noted that Pante only consigned the balance on September 23, 1995 and treated his delay as fatal to his claim. Pante appealed to the Court of Appeals. In its May 18, 2006 decision the Court of Appeals reversed the RTC, holding the contract to be a contract of sale (ownership having passed to Pante), finding no vitiation ...(Pro-only)
Issues:
- Was the Church’s consent to the sale vitiated by misrepresentation or fraud such that the contract with Pante is voidable under Article 1390 of the Civil Code?
- If the contract is not annulled, who prevails in the double sale between Pante and the Rubis under Article 1544 of the Civil Code when neith...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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