G.R. No. 145470 - Spouses Cruz vs. Spouses Ferdo

Petitioners Spouses Luis V. Cruz and Aida Cruz occupied the front portion of a 710-square meter property located in Sto. Cristo, Baliuag, Bulacan.
Respondents Spouses Alejandro Fernando, Sr. and Rita Fernando filed a complaint for accion publiciana (action for recovery of possession) demanding petitioners to vacate the premises and pay reasonable monthly rent.

Respondents purchased the property from Spouses Clodualdo and Teresita Glorioso via a Deed of Sale dated March 9, 1987.
Prior to respondents’ acquisition, the Gloriosos had offered to sell the rear portion of the property to petitioners per a Kasunduan dated August 6, 1983, executed before the Barangay Captain.
Petitioners failed to purchase the rear portion within the negotiated terms, prompting Gloriosos to sell the entire property to respondents.

Respondents filed the complaint on October 21, 1994.
Petitioners filed a Motion to Dismiss, which was denied by the RTC on March 6, 1995.
Petitioners answered asserting:

The Kasunduan was a perfected contract of sale.
They partially consummated the sale by already relocating their house from the rear portion to the front portion they occupied.
Mrs. Glorioso blocked full consummation by refusing to survey exact boundaries.
Respondents bought in bad faith with full knowledge of the prior sale to petitioners.

RTC rendered a decision on April 3, 1998 in favor of respondents, ordering petitioners to vacate, pay P500 monthly rent from the filing date, and dismissing petitioners’ counterclaim.

The Court of Appeals affirmed the RTC decision on October 3, 2000.
Petitioners elevated the matter to the Supreme Court, raising several issues challenging the characterization of the Kasunduan, the remedies employed, and the validity of the respondents’ title and claim.

Gloriosos agreed to sell petitioners a portion of the land of approximately 213 square meters at P40.00 per square meter.
The title to be issued would reflect a total area of 223 square meters; 10 square meters to be used as right of way.
The right of way was to be 1.75 meters wide from Lopez Jaena road to the rear part of the lot where petitioners would build their house.
Surveying expenses and title issuance costs were to be shared equally, each side paying not less than P400.00.
Petitioners were to relocate their house to the bought or to be bought portion by January 31, 1984.

Whether the Court of Appeals erred in holding that the Kasunduan was a mere offer to sell and not a perfected contract of sale.

Whether the Court of Appeals was wrong in not holding that petitioners could have the court fix a period for payment of the price instead of respondents resorting to accion publiciana.

Whether the Court of Appeals erred in not ordering respondents to deliver the rear portion upon petitioners’ payment, assuming the rear portion was the subject of the sale.

Whether the Court of Appeals erred in affirming the order for petitioners, as possessors in good faith, to pay monthly rentals for the occupied portion.