Case Digest (G.R. No. 263047) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The petitioners, Spouses Noel John M. Kaw and Josephine Caseres-Kaw, owned a 3,040 square meter parcel of land in Cagmanaba, Oas, Albay, designated as Lot F in TCT No. T-158628. In February 2014, through their dentist colleague Ivy Orolfo, they met respondents interested in buying a portion (2,000 square meters) of Lot F at PHP 1,200,000. The parties agreed to sell this in two equal portions of 1,000 square meters each for PHP 600,000. The Spouses Kaw executed two Deeds of Conditional Sale on March 10 and March 29, 2014, respectively, with respondents, stipulating an initial PHP 300,000 down payment and the balance due within six months. The contract gave the vendees beneficial occupancy and right to improve the property upon payment of the down payment, but gave the vendors a right of unilateral rescission if the vendees defaulted or breached terms. In April 2014, the petitioners found extensive improvements on the property, including cottages, fencing, and a resort business, w Case Digest (G.R. No. 263047) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Spouses Noel John M. Kaw and Josephine Caseres-Kaw (Spouses Kaw), owners of a 3,040 square meter parcel of land (Lot F, TCT No. T-158628) located in Cagmanaba, Oas, Albay.
- Respondents: Heirs of Marilyn Nodalo, Manuel S. Olaso III, Lea Lim-Tidma, Nerissa S. Orejo, Zenaida Chiquillo, Ivy Orolfo, Ronnie Gomez, Gina Nuarin, all vendees.
- Initial Agreement and Sale
- In February 2014, Spouses Kaw agreed to sell a 2,000 sqm portion of the property to respondents for PHP 1,200,000.00.
- Respondents offered to buy in two portions of 1,000 sqm, for PHP 600,000 each, with PHP 300,000 as down payment.
- Two Deeds of Conditional Sale were executed on March 10 and March 29, 2014, covering two 1,000 sqm portions.
- Orolfo acted as agent, receiving PHP 35,000 as commission.
- The Deeds contain provisions on downpayment, balance payment within 6 months, beneficial possession, improvement rights, and rescission clauses.
- Alleged Breach and Spouses Kaw's Complaints
- Spouses Kaw discovered respondents had built cottages and operated a beach resort with rental activities, allegedly without their consent.
- Spouses Kaw filed a Complaint for Rescission of Contract on September 29, 2015, asserting violations of the Deeds.
- Respondents' Position
- Denied breach; claimed the Deeds allowed improvements and operation of the resort.
- Asserted Spouses Kaw accepted verbal agreements about intended improvements.
- Argued Spouses Kaw refused to accept balance payments.
- Asserted compensatory counterclaims for payment acceptance, execution of deeds of sale, and moral damages.
- Consignation Cases
- Nodalo and Chiquillo filed complaints for consignation alleging Spouses Kaw refused to accept payment.
- The Rescission Case was filed separately by Spouses Kaw.
- Trial Court and CA Decisions
- RTC dismissed Spouses Kaw’s Complaint and granted respondents’ counterclaims, ordering execution of deeds of sale and acceptance of payments.
- CA affirmed RTC, deleted moral damages award.
- Spouses Kaw filed petition before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in dismissing the Complaint for Rescission of the Deeds of Conditional Sale.
- Whether respondents committed forum shopping by filing counterclaims in the Rescission Case while consignation cases were pending.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)