Adm. Case No. 111 - Eduardo R. Santos vs. Hon. Manolo L. Maddela

On July 12, 1978, petitioners, through their authorized agent Atty. Pedro C. Gamboa, sent a letter to “Yao King Ong & tenants” offering to sell land and building in Tacloban City for ₱6,500,000, giving them a preferential option to decide by July 31, 1978.
Respondents replied by telegram: “we agree to buy property proceed Tacloban to negotiate details.”

On July 27, 1978, Gamboa wired respondents: “PROPOSAL ACCEPTED ARRIVING TUESDAY MORNING WITH CONTRACT PREPARE PAYMENT BANK DRAFT.”
On August 1, 1978, Gamboa arrived in Tacloban with a prepared contract. Respondents refused to sign and returned the bank draft because the draft stipulated a 30-day payment for the ₱4,500,000 balance instead of the 90 days they claimed was agreed.

Respondents filed a complaint for specific performance, alleging a perfected contract at ₱6,500,000 with ₱2,000,000 down and ₱4,500,000 within 90 days.
Petitioners moved to dismiss for failure to state a cause of action and unenforceability under the Statute of Frauds.
The trial court denied the motion, ruling that the letters and telegrams attached to the complaint constituted a sufficient memorandum under the Statute of Frauds.
Petitioners elevated the case by certiorari and prohibition to the Supreme Court, challenging the trial court’s orders of November 2, 1978 and August 29, 1980.

Does the complaint state a cause of action for specific performance of a contract of sale?
Is the alleged contract enforceable under the Statute of Frauds?