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Amendments: The original complaint was amended to seek specific performance, which superseded the original claims for rescission.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
Case Syllabus (G.R. No. 205113)
Case Overview
- The case revolves around a petition for review on certiorari under Rule 45 of the Rules of Court.
- The petitioners, Honorlita Ascano-Cupino and Flaviana Ascano-Colocado, challenged the Decision dated July 17, 2012, and Resolution dated January 8, 2013, of the Court of Appeals (CA), which reversed the earlier ruling of the Regional Trial Court (RTC).
- The RTC had initially ruled in favor of the petitioners, canceling the contract with the respondent, Pacific Rehouse Corporation.
Background of the Case
- On October 1, 1994, the Ascanos entered into a Deed of Conditional Sale with Pacific for a parcel of land in General Trias, Cavite, valued at P5,975,300.
- The purchase involved a down payment of P1,792,590, with further payments contingent upon the fulfillment of specific conditions, including the removal of tenants from the property.
- Subsequent to the initial agreement, the Ascanos requested additional payments to facilitate the contract conditions, which Pacific complied with.
- Despite initial compliance, the Ascanos later failed to provide necessary documents or fulfill their obligations under the contract, leading to Pacific's demand for compliance and eventual legal action.
Legal Proceedings
- Pacific initially filed a Complaint for Cancellation of Contract and Damages in September 1999, which was amended to include a request for specific performance.
- The RTC ruled in favor of the Ascanos on April 15, 2005, ordering the cancellation of t