Case Digest (G.R. No. 165133) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Joselina A. Alcantara and Antonio Alcantara and Spouses Josefino Rubi and Annie Distor-Rubi (petitioners) versus Brigida L. Nido, as attorney-in-fact of Revelen N. Srivastava (respondent), petitioners entered into an oral agreement in March 1984 to purchase 200 square meters of an unregistered 1,939-square-meter lot in Cardona, Rizal, owned by Revelen. They paid a P3,000 down payment and agreed to pay the balance in installments. In 1985 they built houses on the lot, and with respondent’s consent, they occupied an additional 150 square meters in 1986. By 1987 petitioners had paid P17,500 but later defaulted. On May 11, 1994, respondent, as Revelen’s administrator and attorney-in-fact, filed before the Regional Trial Court (RTC) of Binangonan, Rizal, a complaint for recovery of possession with damages and prayer for preliminary injunction. On June 17, 2002, RTC Branch 69 declared the oral sale void for lack of written authority under Article 1874 of the Civil Code, res Case Digest (G.R. No. 165133) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Revelen N. Srivastava (Revelen) owns an unregistered 1,939-sqm lot in Cardona, Rizal. Brigida L. Nido (respondent) acts as Revelen’s administrator and attorney-in-fact. Petitioners are Spouses Joselina and Antonio Alcantara and Spouses Josefino Rubi and Annie Distor-Rubi.
- Petitioners initially negotiated with respondent to purchase a 200-sqm portion of the lot at ₱200/sqm in March 1984. They paid ₱3,000 downpayment, with the balance in installments, and built houses in 1985.
- Additional Occupation, Default, and Lower Court Proceedings
- In 1986, with respondent’s consent, petitioners occupied an extra 150 sqm. By 1987, they had paid a total of ₱17,500 before defaulting on installments.
- On May 11, 1994, respondent filed in RTC Branch 69, Binangonan, Rizal a complaint for recovery of possession with damages and preliminary injunction.
- RTC Decision (June 17, 2002): Held the oral sale void under Art. 1874, Civil Code (no written authority), ordered mutual restitution (petitioners to vacate; respondent to return ₱17,500), and awarded respondent attorney’s fees (₱20,000), litigation expenses (₱15,000), and costs.
- Court of Appeals Decision (June 10, 2004): Treated case as unlawful detainer, found RTC lacked jurisdiction (assessed value ₱4,890
Issues:
- Whether the appellate court erred in ruling that the sale contract executed by respondent was void rather than merely voidable.
- Whether petitioners were entitled to their counterclaims, specifically specific performance.
- Whether the RTC had jurisdiction over the complaint for recovery of possession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)