Case Summary (G.R. No. L-14714)
Relevant Facts and Antecedents
The dispute arises from a series of property transactions beginning with the sale of land by Isidro Fenis to Eustaquia Llanes on June 13, 1934, which included a right of repurchase. After the timeframe for repurchase expired, the land was sold again to Maria Viloria, who subsequently sold it to Melencio Manansala with a notation of a right to repurchase, later confirmed through registration of title. Eventually, Andaya and Cabrito, along with their co-vendee, purchased the land from Manansala, fully aware that the property was subject to litigation with Eustaquia Llanes, who was claiming rights to it by virtue of her earlier transaction with Fenis.
Lower Court Proceedings
After being evicted from the land via a final judgment in Civil Case No. 399, Andaya and Cabrito filed a case against Manansala, seeking damages for breach of warranty of title due to eviction. The lower court ultimately ruled that the plaintiffs' acquisition from Manansala was made to facilitate the registration of their prior deed of sale and that Manansala's warranty was effectively pro forma given the litigation surrounding the property. The court ordered Manansala to return half of the purchase price along with interest to the plaintiffs.
Core Legal Issues and Appeals
Manansala appealed the lower court's decision, asserting that he was not liable for damages as there was no breach of warranty against eviction, given the circumstances of the sale and the plaintiffs' awareness of the associated risks. The appeal raised crucial questions regarding vendor liability, the implications of waiving rights to warranty against eviction, and the appropriateness of rescission as a remedy.
Supreme Court Decision
The Supreme Court reversed the lower court's ruling, finding merit in Manansala's arguments. The Court noted that the plaintiffs had waived their right to a warranty against eviction by purchasing the property with full knowledge of the existing litigation. Furthermore, the Court indicated that under the applicable provisions of the old Civil Code and the principles governi
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Case Background
- The case originally commenced in the Court of Appeals and was forwarded to the Supreme Court due to its legal question implications.
- The antecedents of the case were undisputed and outlined as follows:
- On June 13, 1934, Isidro Fenis sold a parcel of land to Eustaquia Llanes with a right of repurchase valid for five years.
- After five years, Fenis sold the same property to Maria Viloria on January 13, 1944, without repurchasing it from Llanes.
- Viloria subsequently sold the property to Melencio Manansala on August 21, 1944, under a sale with right of repurchase for one year.
- Manansala registered his title on the property on August 1, 1946, after the expiry of the repurchase period.
- On September 28, 1947, Viloria executed an absolute sale of the same property to Ciriaco Casino, Fidela Valdez, and the plaintiffs, Ariston Andaya and Micaela Cabrito, for P4,800.
- A civil case (Civil Case No. 399) was instituted by Llanes against Casino to recover possession of the property, leading to a final judgment in favor of Llanes on October 17, 1955.
Legal Proceedings
- Plaintiffs Ariston Andaya and Micaela Cabrito filed a case on March 23, 1956, agains