Case Digest (G.R. No. 147678-87) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Civil Case No. 90-183 filed on January 23, 1990 before the Regional Trial Court, Branch 61, Makati, Starbright Sales Enterprises, Inc. (private respondent) sued The Holy See, represented by the Papal Nuncio, along with Msgr. Domingo A. Cirilos, Jr., Philippine Realty Corporation (PRC) and Tropicana Properties and Development Corporation, for annulment of sale, specific performance and damages. The dispute arose from an April 17, 1988 agreement made by Msgr. Cirilos, Jr., as agent of both the Holy See and PRC, to sell three contiguous parcels in Parañaque—including Lot 5-A (6,000 sq. m.)—at ₱1,240 per square meter on condition that ₱100,000 earnest money be paid and the sellers clear existing squatters. Ramon Licup paid the earnest money and promptly assigned his rights to Starbright, which demanded eviction of squatters. When the sellers declined and instead returned the earnest money while insisting on full payment, Starbright complied but later learned that on March 30, 198... Case Digest (G.R. No. 147678-87) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: The Holy See, sovereign over Vatican City, represented in the Philippines by the Papal Nuncio.
- Private Respondent: Starbright Sales Enterprises, Inc., domestic real estate corporation.
- Other Defendants: Msgr. Domingo A. Cirilos, Jr. (agent), Philippine Realty Corporation (PRC), Tropicana Properties and Development Corporation.
- Real Estate Transactions
- On April 17, 1988, the Holy See and PRC, through Msgr. Cirilos, agreed to sell three contiguous lots (5-A, 5-B, 5-D) in Parañaque to Ramon Licup at ₱1,240/m², subject to ₱100,000 earnest money and eviction of squatters.
- Licup paid the earnest money, then assigned his rights to Starbright, which demanded eviction; sellers proposed either buyer to evict or return earnest money.
- Sellers returned the ₱100,000 and insisted on full cash payment; before payment, on March 30, 1989, the Holy See and PRC sold the lots to Tropicana without notice to Starbright.
- Trial Court Proceedings and Petition
- January 23, 1990: Starbright filed Civil Case No. 90-183 for annulment of sale to Tropicana, reconveyance, specific performance and damages (P30 million).
- June 8, 1990: The Holy See moved to dismiss for lack of jurisdiction (sovereign immunity); Msgr. Cirilos moved to dismiss as improper party.
- June 20, 1991 & September 19, 1991: RTC Branch 61 denied the motions to dismiss and for reconsideration, finding the Holy See “shed off sovereign immunity” by contract.
- December 1, 1994: The Holy See filed a petition for certiorari under Rule 65 to annul the RTC orders.
- Intervention of the Department of Foreign Affairs
- December 9, 1991: DFA moved to intervene and adopt the Holy See’s immunity arguments; its certification affirmed the Holy See’s diplomatic immunity from local jurisdiction.
- Both sides and DFA filed memoranda as directed by the Supreme Court.
Issues:
- Procedural Issues
- Whether certiorari under Rule 65 is available to review the RTC’s order denying the motion to dismiss.
- Whether the DFA has legal interest to intervene on behalf of the Holy See.
- Substantive Issue
- Whether the Holy See enjoys sovereign and diplomatic immunity from suit in Philippine courts for the sale of Lot 5-A, or whether by entering into the contract it waived immunity (i.e., whether the act is jure imperii or jure gestionis).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)