Case Digest (G.R. No. 80511)
Facts:
On April 1, 1977, respondents Evelina Laserna and Gloria Cajipe, represented by attorney-in-fact Proceso F. Cruz, entered into a Contract to Sell with petitioner Solid Homes, Inc. (SHI), a corporation engaged in subdivision development and sale. The contract concerned a parcel of land located at Lot 3, Block I, Phase II, Loyola Grand Villas, Quezon City, with a total area of approximately 600 square meters. The total contract price was ₱172,260.00, payable through a down payment of ₱33,060.00 upon signing and the balance of ₱166,421.88 payable over three years at monthly installments of ₱4,622.83, inclusive of 12% per annum interest. The respondents made the down payment and several monthly payments. When they allegedly had paid 90% of the purchase price, they demanded the execution and delivery of the Deed of Sale and Transfer Certificate of Title (TCT) upon final payment. The petitioner refused to deliver these documents.
Consequently, respondents filed a Complaint for Delive
Case Digest (G.R. No. 80511)
Facts:
- Contract to Sell
- On April 1, 1977, respondents Evelina Laserna and Gloria Cajipe, represented by attorney-in-fact Proceso F. Cruz, entered into a Contract to Sell with petitioner Solid Homes, Inc. (SHI), for a parcel of land (Lot 3, Block I, Phase II, Loyola Grand Villas, Quezon City), approximately 600 square meters.
- Total contract price: ₱172,260.00, payable as follows: ₱33,060.00 down payment upon signing; remaining ₱166,421.88 payable over three years at ₱4,622.83 monthly installments (inclusive of 12% annual interest).
- Respondents paid the down payment and several installments.
- Demand for Deed of Sale and Title
- Upon allegedly completing 90% payment, respondents demanded execution and delivery of the Deed of Sale and Transfer Certificate of Title (TCT) upon final payment.
- Petitioner did not comply with the demand.
- Complaint before HLURB
- On June 28, 1990, respondents filed a Complaint for Delivery of Title and Execution of Deed of Sale with Damages before HLURB (Case No. REM-073090-4511), alleging outstanding balance of ₱5,928.18.
- Petitioner filed an Answer claiming respondents were not yet fully paid and had abandoned the contract, thus consider it rescinded.
- HLURB Arbiter's Decision (October 7, 1992)
- Denied respondents' prayer for Deed of Sale and delivery of TCT.
- Directed petitioner to execute deed and deliver TCT upon full payment.
- Ordered petitioner to cease charging unauthorized fees beyond P.D. No. 957.
- HLURB Board of Commissioners' Decision (August 10, 1994)
- Modified arbitrator's decision: respondents to pay ₱11,585.41 within 30 days from finality.
- Directed petitioner to execute and deliver deed and TCT after full payment.
- Repeated cease-and-desist order on unauthorized fees.
- Office of the President Decision (June 10, 2003)
- Affirmed HLURB Board's Decision in toto by adopting its findings and conclusions by reference.
- Petitioner's motion for reconsideration denied (December 9, 2003).
- Court of Appeals
- Petitioner filed Petition for Review (CA-G.R. SP No. 82153) raising:
- Error in Office of the President adopting HLURB findings by reference without own findings.
- Respondents' complaint lacked cause of action due to non-fulfillment of full payment.
- CA denied petition (July 21, 2004) and denied reconsideration (November 10, 2004).
- Tender of Payment by Respondents
- Respondents tendered ₱11,584.41, representing balance per HLURB decision.
- Petitioner refused to accept tender without justification.
- Respondents did not proceed with consignation.
Issues:
- Whether the Court of Appeals erred in upholding the Office of the President’s decision which merely adopted by reference the findings and conclusions of the HLURB Board of Commissioners without explicitly stating the facts and law on which it was based, allegedly violating the constitutional mandate of Section 14, Article VIII of the 1987 Constitution.
- Whether the Court of Appeals erred in not dismissing the complaint filed by respondents for lack of cause of action, given that respondents had not fully paid the purchase price under the Contract to Sell.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)