Case Summary (G.R. No. 29449)

Contractual Agreement and Payment Terms

• The plaintiff sold two parcels of land to the defendant for a total of P47,000, payable in installments.
• Payment terms included:
  • P5,000 upon signing the contract.
  • P20,000 upon delivery of the Torrens title for the first parcel.
  • P10,000 upon delivery of the Torrens title for the second parcel.
  • P12,000 one year after the delivery of the Torrens title for the second parcel.
• The defendant made the initial payment of P5,000 and subsequently paid P20,000 after receiving the title for the first parcel.
• The defendant failed to pay the agreed amounts for the second parcel, totaling P22,000 claimed by the plaintiff.

Defendant's Allegations and Claims

• The defendant acknowledged the purchase but claimed misrepresentation regarding the area of the second parcel, asserting it was represented as 98 hectares instead of the actual 60 hectares.
• The defendant sought a price reduction to P38,000 based on the alleged misrepresentation and claimed to have paid an additional P4,000.
• The defendant also filed a cross-complaint for P15,000 in damages due to the plaintiff's alleged deceit.

Court's Findings and Rulings

• The trial court found no evidence of fraud or misrepresentation by the plaintiff, concluding that both parties did not consider the area of the land significant in their agreement.
• The court ordered the defendant to pay the plaintiff P19,300 with legal interest, dismissing the defendant's cross-complaint without costs.

Appellate Review and Legal Principles

• The appellate court reviewed the trial court's findings, particularly regarding the alleged deceit and the defendant's understanding of the property area.
• The court noted that the defendant had the opportunity to investigate the property and had received documents indicating the actual area before the contract was executed.
• The court cited legal precedents establishing that a purchaser cannot claim misrepresentation if they had the means to verify the vendor's statements.

Application of Civil Code Article 1471

• The court applied Article 1471 of the Civil Code, which states that in a sale for a lump sum, there is no adjustment of price based on area discrepancies unless the contract specifies otherwise.
• The court concluded that since the sale was fo...continue reading

Case Syllabus (G.R. No. 29449)

Case Background

• The case involves a dispute between Leodegario Azarraga (plaintiff/appellee) and Maria Gay (defendant/appellant) regarding a sale of two parcels of land.
• A public document (Exhibit A) dated January 17, 1921, details the sale for a lump sum of P47,000, payable in installments.
• Payment conditions included:
  • P5,000 upon signing the contract.
  • P20,000 upon delivery of the Torrens title to the first parcel.
  • P10,000 upon delivery of the Torrens title to the second parcel.
  • P12,000 one year after delivery of the second parcel's title.
• The plaintiff received the initial P5,000 and the subsequent P20,000 after delivering the first parcel's title.
• The defendant failed to pay the P10,000 after receiving the title to the second parcel and did not pay the final P12,000 when due.

Claims and Defenses

• The plaintiff claims a total of P22,000, plus legal interest on the unpaid installments from specified dates.
• The defendant admits the purchase but asserts:
  • Misrepresentation regarding the area of the second parcel, which was stated to be 98 hectares but was actually 60 hectares.
  • A demand for price reduction to P38,000 based on the alleged misrepresentation and the actual area.
  • Additional payments of P4,000 beyond what the plaintiff acknowledged.
  • A counterclaim for P15,000 in damages due to the plaintiff's alleged malicious actions in filing the complaint.
...continue reading