Case Digest (G.R. No. 222897) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In August 1991, the AFP Retirement and Separation Benefits System (AFP Retirement System) sold a 240-square-meter parcel known as Lot 20, Block 7, Citadella Subdivision, Las Piñas City, to Edsel B. Lumawag for ₱540,000 payable over ten years. After completing payment in 2000, Edsel demanded the execution of the deed of sale, issuance of the transfer certificate of title, and turnover of possession, but the AFP Retirement System failed to comply, attributing the delay to a re-mapping that reduced the lot’s area by 20 square meters due to the construction by Lourdes Pearce on the adjoining Lot 21. Edsel filed a complaint against both the AFP Retirement System and Lourdes for specific performance and damages, alleging the seller’s refusal to deliver and failure to restrain the encroachment. Lourdes countered that she honestly relied on Sta. Lucia Realty and Development, Inc.’s (Sta. Lucia Realty) relocation survey and building permit, and she impleaded Sta. Lucia Realty for neglige Case Digest (G.R. No. 222897) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Sale
- In August 1991, AFP Retirement and Separation Benefits System (AFP Retirement System) sold Lot 20 (240 sq m) in Citadella Subdivision, Las Piñas City, to Edsel B. Lumawag for ₱540,000 payable over ten years.
- After full payment, Edsel demanded execution of the final deed of sale, transfer of title, and delivery of possession; AFP Retirement System failed to comply.
- Encroachment Dispute
- Lourdes Pearce, owner of adjoining Lot 21, constructed her house encroaching 20 sq m on Lot 20.
- Edsel sued AFP Retirement System and Lourdes for title delivery, possession, and damages; AFP Retirement System suggested lot exchange, admitted non‐execution of the deed due to re‐mapping caused by Lourdes’s encroachment.
- HLURB Proceedings
- HLURB Arbiter (July 5, 2005) ordered AFP Retirement System to execute deed or exchange lots, deliver title to Edsel, and pay moral (₱100,000), exemplary (₱30,000), attorney’s fees (₱30,000), and refund excess payment with 12% interest; ordered Lourdes to pay moral (₱30,000) and attorney’s fees (₱10,000); and Sta. Lucia Realty to pay Lourdes moral (₱100,000), exemplary (₱30,000), attorney’s fees (₱30,000), and expenses.
- HLURB Board of Commissioners (May 25, 2006) dismissed appeals and affirmed the Arbiter.
- Office of the President
- OP Decision (October 23, 2009) affirmed the HLURB decisions; OP Resolution (June 2, 2011) denied motions for reconsideration.
- Court of Appeals
- CA Decision (June 26, 2015) in CA-G.R. SP No. 120161 affirmed HLURB and OP findings, modifying interest on AFP Retirement System’s refund to 6% per annum.
- CA Resolution (February 3, 2016) denied motions for reconsideration.
Issues:
- Did the CA correctly affirm AFP Retirement System’s liability for moral and exemplary damages and attorney’s fees to Edsel?
- Did the CA correctly affirm that Lourdes Pearce is a builder in good faith?
- Should Sta. Lucia Realty be held liable to Lourdes for moral and exemplary damages and attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)