Case Digest (G.R. No. 137909) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In FIDELA DEL CASTILLO VDA. DE MISTICA v. SPOUSES BERNARDINO NAGUIAT AND MARIA PAULINA GERONA-NAGUIAT, decided on December 11, 2003 under the 1987 Constitution, Eulalio Mistica, predecessor-in-interest of petitioner, owned a parcel in Malhacan, Meycauayan, Bulacan, part of which was leased by respondent Bernardino Naguiat in 1970. On April 5, 1979, they executed a Kasulatan sa Pagbibilihan for a 200-square-meter sale at ₱20,000, of which ₱2,000 was paid as downpayment and ₱18,000 was to be paid over ten years, subject to 12% annual interest on unpaid balances. Naguiat paid an additional ₱1,000 on February 7, 1980 but defaulted thereafter. Mistica died in October 1986. On December 4, 1991, petitioner filed for rescission, seeking recovery of the land and rental for unjust occupation, plus attorney’s fees. Respondents countered that the contract allowed payment beyond ten years with interest, tendered payment at the funeral—allegedly refused—and secured a free patent title, making Case Digest (G.R. No. 137909) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties and Property
- Eulalio Mistica owned a parcel of land in Malhacan, Meycauayan, Bulacan; a portion was leased to Bernardino Naguiat in 1970.
- On April 5, 1979, Mistica and Naguiat executed a written “Kasulatan sa Pagbibilihan” for the sale of 200 sqm at P20,000:
- Downpayment of P2,000 upon signing.
- Balance of P18,000 payable within ten years, with 12% yearly interest on any delayed payment.
- Performance and Default
- Naguiat paid the P2,000 downpayment and an additional P1,000 on February 7, 1980; made no further payments.
- Mistica died in October 1986; no demands for the balance were made between 1979 and 1989.
- Trial Court Proceedings
- December 4, 1991: Petitioner Fidela Del Castillo (Mistica’s heir) filed a complaint for rescission, claiming breach, seeking possession, damages for rent (P200/month), and litigation expenses (P20,000).
- Respondents answered, contending:
- Contract provided only for interest, not rescission.
- Title had been awarded to Naguiat by Free Patent, becoming indefeasible.
- Counterclaimed for moral damages (P50,000), exemplary damages (P30,000), and attorney’s fees (P10,000).
- July 8, 1992: Respondents’ motion to dismiss denied; motion for reconsideration denied March 17, 1993.
- January 27, 1995: RTC rendered judgment dismissing petitioner’s complaint, awarding respondents:
- Payment of attorney’s fees (P10,000) and costs of suit.
- Payment of P17,000 balance plus 12% interest from April 5, 1989.
- Return of extra 58 sqm or its value.
- Court of Appeals Decision
- October 31, 1997: CA affirmed RTC with modification—ordering payment for the fair market value of the extra 58 sqm (reconveyance infeasible after registration).
- February 23, 1999: CA denied petitioner’s motion for reconsideration.
- Supreme Court Petition
- Petitioner filed a Rule 45 petition to nullify the CA Decision and Resolution.
Issues:
- Application of Article 1191, New Civil Code
- Does failure to pay the balance within ten years, despite contractual interest provision, constitute a substantial breach justifying rescission?
- Effect of Registration on Rescission
- Does issuance of a certificate of title to respondents preclude the remedy of rescission?
- Reconveyance of Extra Land
- Is reconveyance of the erroneously included 58 sqm feasible, or is payment of its fair market value the only remedy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)