Case Digest (G.R. No. 192947)
Facts:
Petitioners Marito and Maria Fe Serna are the registered owners of two parcels of land in Aramaywan, Quezon, Palawan (OCT Nos. E-6101 and E-6103). In 1995 they agreed to sell these lots to respondents Tito and Iluminada Dela Cruz for ₱300,000.00. On November 9, 1998, the parties executed a handwritten Agreement acknowledging receipt of ₱252,379.27 as partial payment, with a balance of ₱47,621.00. When respondents tendered the remaining sum, petitioners refused to accept it and sought to sell the lots to a third party at a higher price. Respondents filed a complaint for specific performance, damages and attorney’s fees before the Regional Trial Court (RTC), Branch 95, Puerto Princesa City. On April 4, 2014, the RTC ordered petitioners to accept the balance, execute a Deed of Absolute Sale, and pay moral and exemplary damages plus attorney’s fees. The Court of Appeals (CA), in its July 18, 2017 Decision and January 29, 2018 Resolution, affirmed the RTC ruling. Petitioners then el
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Case Digest (G.R. No. 192947)
Facts:
- Background and Subject Properties
- Petitioners Marito and Maria Fe Serna owned two parcels in Aramaywan, Quezon, Palawan (OCT Nos. E-6101 and E-6103).
- Respondents Tito and Iluminada Dela Cruz paid a total of ₱252,379.27 for the purchase of these parcels and on November 9, 1998 executed a handwritten Agreement acknowledging partial payments and a remaining balance of ₱47,621.00.
- Procedural History
- Respondents filed an action for specific performance and damages before the RTC of Puerto Princesa City (Civil Case No. 3612), praying that petitioners be ordered to (a) accept the balance of ₱47,621.00, (b) execute a Deed of Absolute Sale, and (c) pay moral (₱300,000), exemplary (₱100,000), and attorney’s fees (₱50,000 plus ₱1,500 per hearing) and litigation expenses (₱20,000).
- In their Answer, petitioners admitted a prior agreement but asserted that respondents abandoned the sale by failing to pay the balance on agreed dates and that respondents refused the return of their advances.
- On April 4, 2014, the RTC rendered judgment in favor of respondents: petitioners were ordered to accept the balance, execute the deed, and pay ₱20,000 moral damages, ₱10,000 exemplary damages, and ₱10,000 attorney’s fees, finding that ownership had passed upon receipt of more than half the purchase price and that petitioners acted in bad faith.
- On July 18, 2017, the CA affirmed the RTC Decision in toto, holding that (a) the Agreement’s genuineness was established by judicial admission and witness testimony; (b) the Statute of Frauds did not apply to a partially executed contract; and (c) bad faith justified the damages and fees. The CA denied petitioners’ motion for reconsideration on January 29, 2018.
- Petitioners filed a Rule 45 petition with the Supreme Court, contending that (a) respondents failed to prove the Agreement’s execution and (b) the verbal contract is unenforceable under Articles 1356, 1358, and 1403 (Statute of Frauds).
Issues:
- Whether the genuineness and due execution of the handwritten Agreement dated November 9, 1998 have been established.
- Whether the verbal contract of sale is barred by the Statute of Frauds.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)