Case Digest (G.R. No. 264452)
Facts:
Young Scholars Academy, Inc. v. Erlinda G. Magalong, G.R. No. 264452, June 19, 2024, First Division, Hernando, J., writing for the Court.Young Scholars Academy, Inc. (YSAI) filed a Complaint for Specific Performance with Damages on July 26, 2017, against Erlinda G. Magalong over a parcel in Filinvest Subdivision, Batasan Hills, Quezon City (TCT RT-22422). In 2014–2015 YSAI’s representative negotiated for the purchase of the 240 sq. m. lot and on May 18, 2015 executed an Offer to Purchase offering PHP 2,000,000 and paying PHP 40,000 as earnest money (BDO check). Magalong undertook to deliver certified copies of title and related documents within a month but produced only tax certifications. She sent a June 28, 2015 letter requesting documentation reflecting a lower purchase price to reduce capital gains tax; YSAI refused and on September 19, 2015 transmitted a draft Revised Agreement reflecting payment terms proposed by YSAI, which Magalong did not act upon. On October 14, 2015 Magalong sent a “Notice of Decline” returning the earnest money (returned March 15, 2016 by PNB check) and asserting she declined because there was no agreed manner of payment — she had demanded payment by PNB manager’s check rather than post-dated checks.
At trial, Branch 91, Regional Trial Court, Quezon City (Civil Case No. R‑QZN‑17‑08699‑CV) granted YSAI’s complaint on July 26, 2019, ordering Magalong to execute a deed of sale in accordance with the Offer to Purchase, and awarding attorney’s fees and litigation expenses of PHP 81,990.00. Magalong appealed to the Court of Appeals via a Petition for Review on Certiorari under Rule 41.
In CA‑G.R. CV. No. 113870, the Court of Appeals (Fifth Division) reversed on July 15, 2022, holding that no valid contract of sale was perfected because the parties reached an impasse over the terms or manner of payment and thus were still in negotiation; the CA dismissed the Complaint and de...(Pro-only)
Issues:
- Did the parties enter into a valid and perfected contract of sale over the subject property?
- If there is no valid contract, was the RTC’s award of attorney’s fees, litigation expenses, and costs of suit to...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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