Title
Supreme Court
Calilap-Asmeron vs. Development Bank of the Philippines
Case
G.R. No. 157330
Decision Date
Nov 23, 2011
Petitioner failed to pay installments under a deed of conditional sale, leading DBP to rescind and sell the property. SC upheld rescission, ruling terms were clear and breach justified.

Case Summary (G.R. No. L-4616)

Antecedents of the Case

In March 1975, the petitioner and her brother executed a real estate mortgage over two parcels of land to secure a loan from DBP. After failing to fulfill their loan obligations, DBP foreclosed the property, and the parcels were sold to DBP as the highest bidder. The redemption period for the property lapsed in 1981. The petitioner later claimed that DBP had granted her a preferential right to repurchase one of the properties.

Petitioner's Version of Events

The petitioner states that in August 1982, she attempted to negotiate a buy-back of the property but was informed she needed to pay the full purchase price upfront. Under the impression that if she paid two amortizations on the other property, she would be able to reclaim the property covered by TCT No. 164117, she signed a deed of conditional sale for both properties. After fulfilling her payment obligations amounting to P40,000, her request for the release of the property was denied, leading to DBP’s rescission of the deed on August 7, 1985.

Respondents' Version of Events

In contrast, DBP argues that the petitioner intended to repurchase both properties on an installment basis, as indicated by her written communications to DBP. DBP asserts that the petitioner had ample opportunity to adhere to the terms of the deed but failed to do so, thus justifying their rescission of the contract.

Ruling of the Regional Trial Court

The Regional Trial Court dismissed the petitioner’s complaint, reasoning that the evidence and her own written communications indicated she intended to reacquire both properties. The Court emphasized that the terms of the deed clearly expressed this intention and that the petitioner’s subsequent actions affirmed her compliance with its stipulations.

Ruling of the Court of Appeals

On appeal, the petitioner maintained that she had paid a substantial amount towards the purchase price and that her original understanding had been misled. However, the Court of Appeals affirmed the lower court’s ruling, stating that the petitioner had not provided sufficient evidence to support her claims of being misled or to invalidate the rescission by DBP based on her missed amortization payments.

Issues Raised on Appeal

In her appeal to the Supreme Court, the petitioner argued that the Court of Appeals erred in disregarding her testimonial evidence, that she had not given full consent due to misunderstanding the terms of the contract, and that DBP’s rescission was unwarranted given her payments.

Ruling of the Supreme Court

The Supreme Court denied the petitioner’s appeal

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