Case Summary (G.R. No. L-20567)
Factual Background
A Joint Venture Agreement (JVA) was established between the spouses Buencamino and San Juan (landowners) and La Savoie Development Corporation for the development of three parcels into a commercial and residential subdivision. Subsequently, the landowners sold their property to Conde, who later assigned her interests to BPI. An addendum was made to extend the development period to 1997. BPI made several requests to La Savoie to halt lot sales pending the establishment of new prices, but these were ignored. On July 18, 1997, MariAo entered a Contract to Sell with La Savoie, who was to execute a final deed upon full payment.
Legal Proceedings
BPI filed a complaint for termination of the JVA and recovery of properties in February 1998. The RTC issued a preliminary injunction against La Savoie selling unsold lots. Despite completing payment in September 2001, MariAo faced refusal when he sought title delivery from BPI, which claimed La Savoie lacked authority to sell. A decision from the RTC on June 12, 2003, terminated the JVA and ordered La Savoie to turn over possession of the subdivision to BPI.
HLURB and Court of Appeals Rulings
MariAo pursued specific performance with the Housing and Land Use Regulatory Board (HLURB), which ruled in his favor in June 2006, ordering BPI to deliver title and pay damages. The CA affirmed this in August 2006, a decision that went through various appeals, including one to the Office of the President which was rejected.
Issues Raised by Petitioners
BPI raised several arguments in their appeal to the Supreme Court regarding the limitations of La Savoie’s selling authority under the JVA, claiming it was restricted to acts through brokers only. They contended that since they were not parties to the Contract to Sell, MariAo lacked a cause of action against them. BPI additionally argued that the failure to include La Savoie and its president as indispensable parties invalidated the HLURB's decision.
Supreme Court’s Denial of Reconsideration
The Supreme Court initially denied BPI's petition on September 17, 2014, and their subsequent motion for reconsideration in April 2016, asserting there was no substantial argument presented that would warrant a change in its previous ruling. A second motion for reconsideration filed by BPI in June 2016 was deemed prohibited under procedural rules, leading to further refusal by the Court to reconsider their decision.
Examination of the Contractual Authority
The Court reaffirmed that La Savoie had the authority to manage sales under the JVA, as clarified by specific clauses that granted it management responsibilities, including pricing agreement and the capacit
...continue readingCase Syllabus (G.R. No. L-20567)
Factual Background
- The case involves a dispute arising from a Joint Venture Agreement (JVA) between the Spouses Buencamino, Spouses San Juan (landowners), and La Savoie Development Corporation, which aimed to develop three parcels of land in Bulacan into a commercial and residential subdivision known as Buenavista Park Subdivision.
- The pricing of the lots was to be determined jointly by the landowners and La Savoie.
- The landowners sold their property to Josephine Conde, who later assigned her interests to Buenavista Properties, Inc. (BPI).
- An Addendum to the JVA was executed to extend the development period to 1997.
- BPI, through Conde, issued several letters to La Savoie requesting a halt to sales until new prices were agreed upon, which were not heeded.
- A Contract to Sell was executed between Ramon G. MariAo and La Savoie on July 18, 1997, with a provision for a final deed of sale upon complete payment.
- BPI filed a complaint for termination of the JVA and damages against La Savoie on February 28, 1998, leading to a preliminary injunction against further sales.
- MariAo completed payment for his lot on September 19, 2001, but BPI refused to execute the deed of sale, claiming La Savoie acted beyond its authority in selling the lots without BPI's approval.
Procedural History
- The Regional Trial Court (RTC) ruled in favor of BPI on June 12, 2003, terminating the JVA and ordering La Savoie to deliver possession of the subdivision.
- MariAo subsequently filed an action for specific performance at the Housing and Land Use Regulatory Board (HLURB), which ruled in his favor on June 5, 2006, ordering