Case Digest (G.R. No. 137909)
Case Digest (G.R. No. 137909)
Facts:
Fidela Del Castillo Vda. de Mistica v. Spouses Bernardino Naguiat and Maria Paulina Gerona‑Naguiat, G.R. No. 137909, December 11, 2003, Supreme Court First Division, Panganiban, J., writing for the Court.
Petitioner is the heir-in-interest of Eulalio Mistica, who owned a parcel of land in Malhacan, Meycauayan, Bulacan; respondent Bernardino Naguiat had been a lessee of a portion of the land since about 1970. On April 5, 1979, Eulalio Mistica and Bernardino Naguiat executed a written contract of sale (the Kasulatan) for a 200-square‑meter portion of the lot for P20,000, with a downpayment of P2,000 and a further partial payment of P1,000 on February 7, 1980; the balance of P18,000 was agreed payable within ten (10) years and, if not paid within that period, the buyer was to pay interest at 12% per annum until full payment.
Eulalio Mistica died in October 1986. Respondents later alleged they tendered payment of the balance during Mistica’s wake (i.e., within the ten‑year period) but that petitioner refused to accept it. Respondents also claimed they had since acquired a free patent title from the Bureau of Lands, which they asserted made their title indefeasible.
On December 4, 1991, petitioner filed a complaint for rescission of the contract, recovery of possession, rental damages, and attorney’s fees. Respondents answered, denied breach, asserted the remedy was interest under the Kasulatan, and counterclaimed for moral and exemplary damages and attorneys’ fees. Their motion to dismiss was denied by the trial court (order of July 29, 1992; reconsideration denied March 17, 1993). After trial, the Regional Trial Court (Branch unspecified) rendered judgment on January 27, 1995 dismissing petitioner’s complaint, ordering petitioner to pay respondents’ attorney’s fees of P10,000 and costs, and—paradoxically—ordering respondents to pay the balance of P17,000 with 12% interest from April 5, 1989 and to return an extra 58 sq. m. or pay its market value.
The Court of Appeals in CA‑GR CV No. 51067 (Fourth Division) modified and affirmed in substance: it denied rescission, held respondents did not commit a substantial breach because the Kasulatan allowed payment after ten years subject to 12% interest and because petitioner allegedly refused respondents’ tender during the wake; it found reconveyance of the extra 58 sq. m. infeasible because that area had been included in respondents’ registered title and therefore ordered respondents to pay its fair market value. Petitioner sought review by filing a petition under Rule 45. The Court of Appeals’ decision was rendered October 31, 1997; its resolution denying reconsideration was dated February 23, 1999. This Court deemed the case submitted upon receipt of respondents’ memorandum on December 13, 2001; petitioner’s memorandum had been filed October 26, 2000.
Issues:
- Whether petitioner was entitled to rescind the Contract under Article 1191 of the Civil Code for respondents’ failure to pay the balance within the ten‑year period.
- Whether issuance of a certificate of title in respondents’ names bars rescission or otherwise affects petitioner’s remedy.
- Whether reconveyance of the extra 58 square meters included in respondents’ title was feasible and, if not, whether respondents should have been ordered to pay its value.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)