Case Digest (G.R. No. 230817)
Facts:
- Dispute between Vive Eagle Land, Inc. (Vive) and National Home Mortgage Finance Corporation (NHMFC).
- On November 17, 1999, Vive entered into a Deed of Sale with NHMFC to purchase a foreclosed property in Angeles City for P40,000,000.00.
- Payment terms included a 20% downpayment and the balance payable in 10 equal installments with 14% interest per annum.
- Vive paid the first installment of P4,000,000.00 but failed to pay subsequent installments.
- Vive cited issues with the property, such as land awards and its classification as agricultural land under the Comprehensive Agrarian Reform Program (CARP).
- Vive requested a moratorium on payments; NHMFC initially agreed but later rescinded the Deed of Sale due to non-payment.
- Vive filed a complaint for nullity of rescission and other reliefs.
- The Regional Trial Court (RTC) of Makati City, Branch 138, dismissed Vive's complaint.
- RTC Branch 133 granted Vive's motion for reconsideration, but this decision was later reversed by RTC Branch 139.
- The Court of Appeals (CA) affirmed RTC Branch 139's decision.
- Vive filed a Petition for Review on Certiorari before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Deed of Sale was a contract to sell.
- Vive was in default of its payment obligations.
- The rescission of the Deed of Sale by NHMFC was valid.
- The subsequent sale of the property to Cavacon ...(Unlock)
Ratio:
- The Supreme Court ruled that the Deed of Sale was a contract to sell, as NHMFC retained ownership of the property until full payment of the purchase price.
- Vive was aware of the property's issues and assumed responsibility for resolving them.
- Vive's failure to pay the subsequent installments constituted an event of default, giving NHMFC the right to rescind the contract.
- The ...continue reading
Case Digest (G.R. No. 230817)
Facts:
The case involves a dispute between Vive Eagle Land, Inc. (Vive), a corporation engaged in the realty business, and the National Home Mortgage Finance Corporation (NHMFC), a government corporation. On November 17, 1999, Vive entered into a Deed of Sale of Rights, Interests, and Participation Over Foreclosed Assets with NHMFC to purchase a foreclosed property in Angeles City for P40,000,000.00. The payment terms included a 20% downpayment and the balance payable in 10 equal installments with 14% interest per annum. Vive paid the first installment of P4,000,000.00 but failed to pay subsequent installments, citing issues with the property, such as land awards and its classification as agricultural land under the Comprehensive Agrarian Reform Program (CARP). Vive requested a moratorium on payments, which NHMFC initially agreed to but later rescinded the Deed of Sale due to non-payment. Vive filed a complaint for nullity of rescission and other reliefs, which the Regional Trial Court (RTC) of Makati City, Branch 138, dismissed. Vive's motion for reconsideration was granted by RTC Branch 133, but this decision was later reversed by RTC Branch 139. The Court of Appeals (CA) affirmed the RT...