Case Digest (G.R. No. 168325)
Facts:
- The case "Tuazon v. Del Rosario-Suarez" involves a dispute over a parcel of land on Tandang Sora Street, Barangay Old Balara, Quezon City, Philippines.
- On June 24, 1994, Roberto D. Tuazon (petitioner) entered into a three-year lease contract with Lourdes Q. del Rosario-Suarez (respondent), starting in March 1994 and ending in February 1997.
- During the lease, Lourdes offered to sell the property to Roberto for P37,541,000.00, giving him a two-year period from January 2, 1995, to decide.
- Roberto did not accept the offer within the stipulated period.
- On June 19, 1997, Lourdes sold the property to her daughter, Catalina Suarez-de Leon, her son-in-law Wilfredo de Leon, and her grandsons Miguel Luis S. de Leon and Rommel S. de Leon for P2,750,000.00.
- The new owners, through their attorney-in-fact Guillerma S. Silva, notified Roberto to vacate the premises, leading to an unlawful detainer complaint.
- The Metropolitan Trial Court (MeTC) ruled in favor of the new owners, ordering Roberto to vacate the property.
- Roberto filed a complaint with the Regional Trial Court (RTC) for annulment of the sale, reconveyance, damages, and preliminary injunction, which was dismissed.
- The Court of Appeals (CA) affirmed the RTC's decision, prompting Roberto to file a petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the case involves an option contract and not a right of first refusal. The petition was denied, and the decision of the Court of Appeals, which affirmed the RTC's decision, was upheld.
- The failure of the appellee to file an appellee's brief does not automatically result in a decision favorable to the appellan...(Unlock)
Ratio:
- The Supreme Court elucidated that the letter from Lourdes to Roberto dated January 2, 1995, constituted an option contract, granting Roberto a fixed period of two years to purchase the property at a specified price of P37,541,000.00.
- Under Articles 1324 and 1479 of the Civil Code, an option contract necessitates a distinct consideration to be binding. In this instance, there was no acceptance of the offer by Roberto, nor was there a distinct consideration for the option contract.
- Roberto's counter-offer for a lower price was not accepted by Lourdes, and thus no contract was perfected.
- The C...continue reading
Case Digest (G.R. No. 168325)
Facts:
The case involves Roberto D. Tuazon (petitioner) and Lourdes Q. Del Rosario-Suarez, along with her family members, who are the respondents. The events leading to the case began on June 24, 1994, when Roberto and Lourdes entered into a Contract of Lease for a parcel of land located along Tandang Sora Street, Barangay Old Balara, Quezon City, with a lease term from March 1994 to February 1997. During the lease period, on January 2, 1995, Lourdes sent a letter to Roberto offering to sell the property for P37,541,000.00, providing him a two-year period to accept the offer. However, on June 19, 1997, after the lease had expired, Lourdes sold the property to her family members (the De Leons) for only P2,750,000.00. The De Leons subsequently notified Roberto to vacate the premises, which he refused, leading them to file a complaint for Unlawful Detainer against him in the Metropolitan Trial Court (MeTC) of Quezon City. The MeTC ruled in favor of the De Leons, ordering Roberto to vacate the property due to non-payment of rent and expiration of the lease.
While the ejectment case was on appeal, Roberto filed a Complaint for Annulment of Deed of Absolute Sale, Reconveyance, Damages, and Application for Preliminary Injunction against Lourdes and the De Leons in the Regional Trial Court (RTC) of Quezon City. The RTC later declared Lourdes and the De Leons in default for failing to appear, but this order was set aside upon their motion for reconsideration. After trial, the RTC ruled that the sale to the De Leons was valid, stating that L...