Case Digest (G.R. No. L-21598)
Facts:
Encarnacion Vda. de Valencia, et al. v. Pedro Deudor, et al., G.R. No. L-21598, promulgated May 19, 1966, the Supreme Court En Banc, Bengzon, J.P., J., writing for the Court. Plaintiffs-appellants were Encarnacion Zafra Vda. de Valencia and her children, heirs of Andres Valencia; defendants-appellees included Pedro Deudor, his co-defendants, J. M. Tuason & Co., Inc., its agent Gregorio Araneta & Co., Inc., and later the spouses Maximo (referred in the record also as Maximino) Sison and Victoria Enriquez.On February 4, 1949 Pedro Deudor sold a 1,200 sq. m. parcel (Lot 128, Tatalon, Sta. Mesa Heights) to Andres Valencia for P3,600, with P400 down and the balance payable within ten years. The land formed part of a larger tract (206,581 sq. m.) covered by TCT No. 37686 and became subject of litigation in CFI Rizal, Q-135, between the Deudors and J. M. Tuason & Co., Inc. A Compromise Agreement dated March 16, 1953 in Q-135 listed Andres Valencia among purchasers with the right to continue occupying or buying the lands allocated to them.
After Andres Valencia’s death in 1952, his heirs tendered P2,439.93 as the alleged unpaid balance, but the Deudors and J. M. Tuason & Co., Inc. refused, insisting on a new contract at a higher price under the Compromise. On February 3, 1956 the heirs filed a complaint in the CFI of Rizal (Quezon City branch) for specific performance with damages against the Deudors, J. M. Tuason & Co., Inc., and Gregorio Araneta & Co.; procedural motions followed, including a denied motion to dismiss by Tuason and an answer in April 1956.
In March 1961 the plaintiffs obtained a writ of preliminary injunction against the Sison spouses, who claimed title through J. M. Tuason & Co., Inc., after the Sisons allegedly removed fences and began construction on the disputed portion. Plaintiffs amended their complaint on April 8, 1961 to add the Sison spouses as defendants, alleging they, acting in bad faith under an October 10, 1959 purported contract of sale from Gregorio Araneta, sought to despoil plaintiffs of the parcel. The trial court admitted the amended complaint but, after the Supreme Court decisions holding the Deudor–Tuason Compromise rescinded (citing Deudor v. Tuason, L-13768, May 30, 1961 and J. M. Tuason & Co., Inc. v. Sanvictores, L-16836, Jan. 30, 1962), it dismissed the amended complaint as to the Sison spouses on April 11, 1962 on the ground that plaintiffs’ purported preferential right...(Pro-only)
Issues:
- Does the amended complaint, for purposes of a motion to dismiss, state a cause of action against the spouses Maximo Sison and Victoria Enriquez?
- If the Deudor–Tuason Compromise Agreement has been rescinded by prior Supreme Court decisions, does that extinguish any cause of action the Valencia heirs have based on the February 4, ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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