Case Digest (G.R. No. 172036)
Case Digest (G.R. No. 172036)
Facts:
Spouses Faustino and Josefina Garcia, Spouses Meliton and Helen Galvez, and Constancia Arcaira represented by their Attorney-in-Fact Juliana O. Motas, petitioners, filed G.R. No. 172036, decided April 23, 2010, by the Supreme Court Second Division, Carpio, J., writing for the Court. They sought review under Rule 45 of the Court of Appeals Decision (CA‑G.R. CV No. 63651) dated January 25, 2006 and its March 16, 2006 Resolution, which had reversed Branch 23, Regional Trial Court (RTC) of Trece Martires City, Cavite, in Civil Case No. TM‑622. Respondents are the Court of Appeals, Emerlita Dela Cruz, and Diogenes G. Bartolome.On May 28, 1993, petitioners and Emerlita Dela Cruz entered into a Contract to Sell for five parcels in Tanza, Cavite, for P3,170,220.00. Petitioners paid P500,000.00 down and agreed staged payments culminating in P1,670,220.00 due December 31, 1993. Three of the lots (Lots 2776, 2767 and 2769) were at that time still registered in the name of one Angel Abelida; petitioners were told they would shoulder expenses for transfer from Abelida to Dela Cruz.
Petitioners failed to pay the final installment on December 31, 1993. They tendered payment in July 1995, but Dela Cruz refused to accept it. On September 23, 1995, Dela Cruz sold the same parcels to intervenor Diogenes Bartolome for P7,793,000.00. Petitioners then filed a complaint for specific performance (and attacked the Abelida–Dela Cruz deed as spurious), while Bartolome intervened asserting he purchased in good faith.
The RTC (Decision dated April 15, 1999) held Dela Cruz’s attempted rescission invalid, applied Republic Act No. 6552 (Maceda Law), found petitioners justified in withholding payment because of alleged spurious title, declared Bartolome not a purchaser in good faith, ordered Dela Cruz to accept payment of P1,670,220.00 and execute the deed, voided the sale to Bartolome and awarded damages and attorney’s fees. Dela Cruz and Bartolome appealed.
The Court of Appeals reversed and dismissed Civil Case No. TM‑622 (Jan. 25, 2006), holding petitioners’ failure to pay on the stipulated date entitled Dela Cruz to rescind pursuant to the contract and that no judicial action was necessary to effect rescission where the contract provided for automatic revocation; it ordered only the return to petitioners of amounts in excess of one‑half percent of P1,500,000.00. Petitioners’ motion for reconsideration was denied (Mar. 16, 2006), prompting this Rule 45 petition.
Issues:
- Did the Court of Appeals err in not applying Republic Act No. 6552 (Maceda Law) to protect petitioners?
- Were petitioners justified in suspending payment because Dela Cruz could not pass title at the time of the Contract to Sell?
- Was Dela Cruz’s extrajudicial rescission done in bad faith so as to render the rescission invalid?
- Was Diogenes Bartolome an innocent purchaser in good faith, or should he be denied protection?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)