Case Digest (G.R. No. 212472)
Facts:
In Specified Contractors & Development, Inc. and Spouses Architect Enrique O. Olonan and Cecilia R. Olonan (collectively, petitioners) v. Jose A. Pobocan (respondent), decided January 11, 2018 under the 1987 Constitution, respondent was employed by petitioners until his retirement in March 2011, having served as president of Specified Contractors and its subsidiary, Starland Properties Inc., and executive assistant to other affiliates. He alleged that in 1994 and again in 1999 Architect Olonan orally agreed to give him one condominium unit for every building constructed, which resulted in Unit 208 of Sunrise Holiday Mansion Building I and Unit 708 of Xavierville Square Condominium being assigned to him. Upon his retirement, respondent sent a March 14, 2011 demand letter requesting execution of deeds of assignment or sale, but petitioners failed to act. On November 21, 2011, he filed before the Regional Trial Court (RTC) of Quezon City, Branch 92, Civil Case No. Q-11-70338, a comCase Digest (G.R. No. 212472)
Facts:
- Parties and Proceedings
- Petitioners Specified Contractors & Development, Inc. and Spouses Architect Enrique O. Olonan and Cecilia R. Olonan moved to dismiss respondent Jose A. Pobocan’s complaint for specific performance before the Regional Trial Court (RTC) of Quezon City, Branch 92, Civil Case No. Q-11-70338.
- The RTC granted the motion and dismissed the complaint by Order dated June 4, 2012.
- Background of the Claim
- Respondent was president of Specified Contractors and its subsidiary and executive assistant to other affiliates until his retirement in March 2011.
- He alleged an oral compensation agreement: for every condominium project completed by Specified Contractors, he would receive one unit. Two such projects were Xavierville Square Condominium (Unit 708) and Sunrise Holiday Mansion Building I (Unit 208).
- On March 14, 2011, respondent demanded execution of Deeds of Assignment or Sale for the subject units; upon no response, he filed his complaint on November 21, 2011, praying for specific performance and damages.
- Lower Court Decisions
- Petitioners’ January 17, 2012 Motion to Dismiss argued (a) no enforceable oral agreement (Statute of Frauds) and (b) prescription.
- The RTC agreed on the Statute of Frauds ground, ruling the oral contract must have been in writing, and dismissed the suit. It declined to apply prescription under Articles 1144–1145, treating the action as real and applying a 30-year prescriptive period.
- On appeal, the Court of Appeals (CA) reversed on November 27, 2013, holding partial performance estopped the Statute of Frauds defense and ordering trial on the merits. A Resolution denying reconsideration followed on April 28, 2014.
- Petitioners then elevated the case by Petition for Review on Certiorari under Rule 45 before the Supreme Court, raising: jurisdictional defect (labor arbiter), prescription, and Statute of Frauds.
Issues:
- Jurisdiction
- Whether the RTC had jurisdiction over a claim arising from an employer-employee relationship, allegedly cognizable by the Labor Arbiter.
- Prescription
- Whether the cause of action for specific performance on an oral contract had prescribed.
- Statute of Frauds
- Whether the oral agreement to convey condominium units is unenforceable for lack of written form.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)