Title
Ascano-Cupino vs. Pacific Rehouse Corp.
Case
G.R. No. 205113
Decision Date
Aug 26, 2015
Petitioners failed to fulfill obligations under a conditional land sale; Supreme Court upheld specific performance, ruling Pacific Rehouse entitled to enforce the contract.
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Case Summary (G.R. No. 205113)

Case Overview

The case involves a petition for review on certiorari filed by Honorlita Ascano-Cupino and Flaviana Ascano-Colocado (petitioners) against Pacific Rehouse Corporation (respondent) regarding the reversal of a Regional Trial Court (RTC) decision by the Court of Appeals (CA). The RTC had canceled a Deed of Conditional Sale and ordered the return of payments made by Pacific. The CA, however, ruled in favor of specific performance.

Legal Principles

  • Deed of Conditional Sale: A legal contract where the seller agrees to sell a property upon certain conditions which must be fulfilled by the seller.
  • Specific Performance vs. Rescission: Specific performance compels a party to fulfill their contractual obligations, while rescission cancels the contract and returns the parties to their pre-contractual positions.

Key Definitions

  • Vendee: The buyer in a contract (in this case, Pacific Rehouse Corporation).
  • Vendor: The seller in a contract (in this case, the Ascanos).
  • Addendum: An addition or amendment to the original contract.

Facts of the Case

  • On October 1, 1994, the Ascanos entered into a Deed of Conditional Sale with Pacific to sell a 59,753 square meter parcel of land for P5,975,300 with specific payment conditions.
  • Payments were made in increments, but the Ascanos failed to deliver necessary documents and sought to rescind the contract.
  • Pacific deposited payment into a bank account for the Ascanos, which the latter withdrew.
  • Pacific filed for cancellation of the contract and later amended its complaint to seek specific performance.

Court Rulings

  • RTC Decision (April 15, 2005): Cancelled the contract and required the Ascanos to return P2,602,000 to Pacific while awarding damages and attorney's fees to the Ascanos.
  • CA Decision (July 17, 2012): Reversed the RTC decision, granting Pacific's appeal for specific performance and ordering the Ascanos to execute a Deed of Absolute Sale.

Requirements and Procedures

  • Obligations of the Parties:

    • Pacific must pay the remaining balance upon fulfillment of the Ascanos' obligations.
    • The Ascanos must provide all documentation necessary for the transfer of property title and remove tenants, for which they are responsible for compensation.
  • Amendments: The original complaint was amended to seek specific performance, which superseded the original claims for rescission.

Relevant Timeframes

  • Payments: The payments made by Pacific included:
    • Down payment: P1,792,590
    • Additional payments totaling P2,705,180.
  • Balance Due: Total balance after payments was P1,577,530 upon fulfillment of obligations.

Penalties and Liabilities

  • The Ascanos were liable for the return of the payments received if the contract was rescinded.
  • If obligations were fulfilled, Pacific would be liable for the balance payment.

Cross-References

  • Civil Code Article 1191: Establishes the right to rescind obligations in reciprocal contracts when one party fails to comply.

Key Takeaways

  • The CA affirmed that Pacific, as the party that fulfilled its obligations, was entitled to specific performance rather than rescission.
  • The Ascanos failed to meet their obligations concerning tenant removal and

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