Case Summary (G.R. No. 167071)
Facts of the Case
The assignment of rights executed on 11 September 1981 stipulated that Ampeloquio would compensate Napiza with 5% of the disposable area of the property in exchange for his assistance in convincing co-owners to develop the land. Dispute arose over whether the subject matter of this contract pertained to the Palolang Malapit property, as asserted by Napiza, or the Palolang Malayo property, as claimed by Ampeloquio. Conflicting accounts regarding the execution and implications of the contract led to the filing of a complaint for specific performance by Napiza, demanding his entitled commission.
Judicial Proceedings
The Regional Trial Court (RTC) ruled in favor of Napiza, affirming that the Assignment of Rights referred to the Palolang Malapit property and not the Palolang Malayo. The RTC found Ampeloquio liable for a commission and ordered the delivery of the specified land along with attorney's fees. Ampeloquio's subsequent appeal to the Court of Appeals resulted in an affirmation of the RTC’s decision, with the attorney's fees being reduced.
Issues Raised
In his petition, Ampeloquio raised several issues:
- Whether the findings of the lower courts were contrary to the evidence and misapprehended facts.
- Whether the action had prescribed under the relevant civil law.
- Whether Napiza had a legal right to compensation given alleged regulatory violations.
- Whether the parties were in pari delicto, affecting Napiza's ability to recover.
Legal Findings
The Supreme Court upheld the findings of the RTC and the Court of Appeals, stating that the evidence clearly supported that the Assignment of Rights concerned the Palolang Malapit property. On the issue of prescription, the Court held that the action was initiated within the ten-year period as prescribed by the Civil Code, beginning only after Ampeloquio denied obligations arising from the Assignment of Rights. The Court also affirmed that Napiza’s prior demands interrupted any running prescription of his claim.
Additional Contentions
Ampeloquio's arguments regarding prohibition of service due to lack of licensing were dismissed since this issue was not previously raised in the tria
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Case Overview
- This case involves a Petition for Review under Rule 45 of the Rules of Court filed by Rudy S. Ampeloquio, Sr. against Romeo Napiza, challenging the decisions of the Court of Appeals and the Regional Trial Court (RTC) regarding a dispute over a contractual agreement relating to real estate development.
Background of the Case
- Rudy S. Ampeloquio, Sr. is a real estate developer, while Romeo Napiza is a co-owner of a parcel of land in Lucban, Quezon.
- The core issue revolves around the "Assignment of Rights" executed on September 11, 1981, where Napiza was to receive a 5% commission for persuading co-owners to develop a property.
- The subject properties include:
- Lot No. 3424 (Palolang Malapit property) covered by Original Certificate of Title No. P-10786.
- Lot No. 3445 (Palolang Malayo property).
Contractual Agreements
- The "Assignment of Rights" stipulated that the 5% of the property for Napiza would be deducted from Ampeloquio’s share as the developer.
- There was also a handwritten unnotarized instrument that outlined the agreement regarding the development of the Palolang Malapit property.
- The parties agreed that Ampeloquio would retain 55% of the developed lots while the remaining 45% would belong to the co-owners.
Dispute and Proceedings
- Napiza claimed Ampeloquio failed to fulfill his obligat