Case Digest (G.R. No. 210475)
Facts:
In Spouses Onnie Serrano and Amparo Herrera v. Godofredo Caguiat (G.R. No. 139173, February 28, 2007), petitioners Spouses Serrano and Herrera are the registered owners of a 439-square-meter lot in Las Piñas, Metro Manila, covered by Transfer Certificate of Title No. T-9905. In March 1990, respondent Godofredo Caguiat offered to buy the lot at ₱1,500 per square meter. On March 19, 1990, he paid ₱100,000 as partial payment and received a Receipt for Partial Payment stating that he would pay the balance on or before March 23, 1990 and that the parties would execute and sign the final Deed of Sale on that date. On March 28, 1990, respondent’s counsel notified petitioners of his readiness to pay the balance and requested preparation of the final deed. On April 4 and April 6, 1990, petitioners, through counsel, purported to cancel the transaction and returned the ₱100,000 by manager’s check. In response, respondent filed a complaint for specific performance and damages in the RegionaCase Digest (G.R. No. 210475)
Facts:
- Parties and Property
- Spouses Onnie Serrano and Amparo Herrera (petitioners) are the registered owners of a 439-sqm lot in Las Piñas, Metro Manila, under TCT No. T-9905.
- Godofredo Caguiat (respondent) expressed interest in March 1990 to purchase the lot at ₱1,500.00 per square meter.
- Partial Payment and Receipt
- On March 19, 1990, respondent paid ₱100,000.00 as partial payment.
- Petitioners issued a “Receipt for Partial Payment” stating:
- The amount received was ₱100,000.00 as partial payment of the lot.
- Respondent promised to pay the balance and execute the final deed of sale on or before March 23, 1990.
- Subsequent Correspondence and Cancellation
- March 28, 1990 – Through counsel, respondent informed petitioners of his readiness to pay the balance and requested preparation of the deed of sale.
- April 4, 1990 – Petitioners’ counsel notified respondent that Amparo Herrera would depart abroad by April 15, 1990, and unilaterally canceled the transaction, offering to return the ₱100,000.00.
- April 6, 1990 – Petitioners delivered to respondent’s counsel a manager’s check for ₱100,000.00, effecting the return of the earnest money.
- Trial Court Proceedings
- Respondent filed for specific performance and damages before the RTC, Makati (Civil Case No. 90-1067).
- June 27, 1994 – The trial court found a perfected contract of sale, citing Article 1482 on earnest money as proof of perfection, and ordered petitioners to execute the final deed of sale.
- January 29, 1999 – The Court of Appeals affirmed the RTC decision; its resolution denying reconsideration issued July 14, 1999.
- Supreme Court Review
- Petitioners filed a Rule 45 petition, questioning whether the partial-payment receipt constituted a perfected contract of sale or merely a contract to sell.
- Central contention: absence of clear agreement on the full price and the lack of a formal deed of sale prevented perfection of the contract under Articles 1458, 1475, and 1482 of the Civil Code.
Issues:
- Whether the “Receipt for Partial Payment” is a contract of sale or a contract to sell.
- Whether the payment of ₱100,000.00 perfected the contract under Article 1482 of the Civil Code.
- Whether respondent can compel specific performance given the nature of the parties’ agreement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)