Case Digest (G.R. No. 172927) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rosencor Development Corporation and Rene Joaquin v. Paterno Inquing, et al., respondents Paterno Inquing, Irene Guillermo, and Federico Bantugan (later joined by Fernando Magbanua and Danna Lizza Tiangco) alleged that since 1971 they had an oral lease of a two-story residential apartment at No. 150 Tomas Morato Ave., Quezon City, paying P150 a month (later P1,000), and that the late spouses Faustino and Cresencia Tiangco, and subsequently their heirs represented by Eufrocina de Leon, verbally granted them a right of first refusal if the property were sold. In June 1990 respondents received letters from Atty. Erlinda Aguila demanding they vacate, then in October 1990 De Leon offered the property at P2,000,000, which respondents counter-offered at P1,000,000. Unbeknownst to them, on September 4, 1990 De Leon had already executed a Deed of Absolute Sale to Rosencor and Rene Joaquin for P726,000. Upon discovering the sale in April 1992 and their exclusion from the transaction, r Case Digest (G.R. No. 172927) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioners: Rosencor Development Corporation and Rene Joaquin; Respondents: Paterno Inquing, Irene Guillermo, Federico Bantugan; intervenors Fernando Magbanua and Lizza Tiangco.
- Complaint filed December 10, 1993 originally for annulment of a Deed of Absolute Sale, later amended to one for rescission; complaint-in-intervention by Magbanua and Tiangco admitted May 4, 1994.
- Lease and Pre-emptive Right
- Since 1971 respondents leased a two-story residential apartment at No. 150 Tomas Morato Ave., Quezon City, for ₱150/month; alleged oral grant by spouses Tiangco of a pre-emptive right to purchase.
- After spouses Tiangco died in 1975, heirs represented by Eufrocina de Leon allegedly recognized the same right; respondents spent ₱50,000–₱100,000 on improvements; rent rose to ₱1,000/month.
- Transactions Leading to Sale
- June 1990: Atty. Aguila, counsel for de Leon, demanded respondents vacate; de Leon refused rent payments; offered property at ₱2,000,000; respondents counteroffered ₱1,000,000; de Leon did not respond.
- September 4, 1990: De Leon sold property to Rosencor for ₱726,000; respondents discovered sale in April 1992, offered to complete ₱1,000,000 but were refused; filed action for rescission and reconveyance.
- Lower Courts’ Decisions
- RTC Decision dated May 13, 1996 dismissed complaint, holding the oral right unenforceable under the Statute of Frauds (Art. 1403, NCC); ordered respondents to pay back rent.
- CA Decision dated June 25, 1999 reversed the RTC, ordered rescission of the sale, reconveyance to de Leon, a 30-day period for respondents to exercise their right at ₱1,000,000, and payment of back rent by respondents.
Issues:
- Whether the Statute of Frauds (Art. 1403, NCC) applies to an oral right of first refusal over real property.
- Whether respondents sufficiently proved their oral right of first refusal.
- Whether a sale in violation of a third party’s right of first refusal may be rescinded when the purchaser acts in good faith.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)