Title
Cebu Bionic Builders Supply, Inc. vs. Development Bank of the Philippines
Case
G.R. No. 154366
Decision Date
Nov 17, 2010
Cebu Bionic claimed a right of first refusal after DBP foreclosed and sold the property, but the court ruled no valid lease or enforceable right existed post-foreclosure.
A

Case Summary (G.R. No. 154366)

Procedural History

The Regional Trial Court (RTC), Branch 8, Cebu, rendered judgment on April 25, 1997 in Civil Case No. CEB-10104 in favor of petitioners (rescinding DBP’s deed of sale to respondents To Chip, Yap and Balila and ordering DBP to execute a deed of sale to petitioners). The Court of Appeals (CA) initially affirmed the RTC in a decision promulgated February 14, 2001. Respondents To Chip, Yap and Balila filed a motion for reconsideration with the CA more than six months after receipt of that decision; the CA admitted the late motion on February 5, 2002 and, by an Amended Decision dated July 5, 2002, reversed the RTC and dismissed petitioners’ complaint. Petitioners then filed the present Rule 45 petition to the Supreme Court, which considered both procedural and substantive issues.

Factual Background

Rudy and Elizabeth Robles mortgaged a parcel in Tabunoc, Talisay, Cebu to DBP (loan P500,000) on June 2, 1981. Robles leased a portion (the subject commercial unit) to Cebu Bionic under an October 28, 1981 lease containing, among other terms, a clause giving the lessee a first option to buy and to match offers from outside parties. DBP foreclosed and became the owner by foreclosure sale on February 6, 1987; a final deed of sale issued October 13, 1988. On June 18, 1987 DBP sent a letter to petitioners notifying DBP’s acquisition and advising petitioners that, if they wished to continue leasing, they should execute a new lease at DBP with stated salient conditions and that failure to sign within 30 days would be construed as lack of interest and would require vacatur. Petitioners’ counsel replied (July 7, 1987) with a counter-proposal; no written lease with DBP was executed. DBP offered the property for sale under a negotiated-sale 15-day acceptance period that closed 12:00 noon December 3, 1990. Petitioners submitted a letter-offer on the morning of December 3, 1990 with a manager’s check for 10% of the offered price; DBP later rejected that submission as insufficient. Respondents To Chip, Yap and Balila submitted a cash offer December 17, 1990 and completed the purchase December 28, 1990. Petitioners received demand letters to vacate in January–February 1991, made a lump-sum rental payment March 22, 1991, and filed this action on April 10, 1991 seeking rescission of the deed of sale, specific performance, cancellation of the respondents’ deed, damages and a preliminary injunction.

Issues Presented to the Supreme Court

Preliminary: (1) Validity of the petition’s verification and certification of non-forum shopping signed by only one petitioner; (2) Whether only questions of law are properly raised in the Rule 45 petition. Principal substantive issues summarized by petitioners included whether the CA erred in admitting the late motion for reconsideration; whether a lease existed between petitioners and DBP continuing the Robles lease; whether any continuing lease included a right of first refusal; whether Article 1670 applies; whether respondents were bound by any right of first refusal; and whether the CA erred in reversing its earlier judgment.

RTC Findings and Ruling

The RTC found that DBP continued the Robles lease by accepting petitioners’ payments and by acting in a way that revived the lease’s terms, including the right of first option to buy. The RTC concluded DBP violated petitioners’ right of first refusal, rescinded the deed of sale of December 28, 1990 between DBP and respondents To Chip, Yap and Balila, and ordered DBP to execute a deed of sale to petitioners upon their payment of the consideration.

Court of Appeals Decisions and Reconsideration

The CA initially affirmed the RTC on February 14, 2001. Respondents To Chip, Yap and Balila filed a motion for reconsideration more than six months after receipt of the CA’s decision; the CA admitted the late motion on February 5, 2002 in the interest of substantial justice and, after reevaluation, issued an Amended Decision on July 5, 2002 reversing the RTC. In the Amended Decision the CA held DBP had effectively terminated the Robles lease by its June 18, 1987 letter, petitioners failed to execute the new lease required by DBP within the stipulated period, no new contract was perfected, and Article 1670’s implied lease doctrine did not revive a right of first refusal as to outside purchasers. Accordingly the CA dismissed petitioners’ claims.

Supreme Court: Admissibility of the Late Motion for Reconsideration

The Supreme Court recognized that, as a general rule, failure to file a motion for reconsideration within the reglementary period renders an appellate decision final. Nonetheless, invoking the Court’s established discretion to relax procedural rules to serve substantial justice (as discussed in Barnes v. Padilla and other authorities), the Court excused respondents’ late filing. The Court found that property rights were at stake, the merits warranted review to settle competing claims of ownership/preferred purchase rights, and other equitable considerations weighed in favor of admitting the late motion; accordingly the CA’s reconsideration and amended judgment were properly entertained on equitable grounds.

Supreme Court: Existence of a Contract of Lease Between Petitioners and DBP

Applying contract principles (Articles 1305, 1315 and 1319: meeting of minds and perfection by consent) and the three-stage view of contract formation (negotiation, perfection, consummation), the Court held no new lease was perfected between DBP and petitioners. DBP’s June 18, 1987 letter invited petitioners to execute a new lease with salient conditions and gave a 30-day period to act; petitioners’ July 7, 1987 correspondence was a counter-offer and the parties did not converge on agreed terms nor execute a written contract within the period. The Court rejected the RTC’s finding that DBP “opted to continue” the Robles lease; rather, DBP’s letter constituted a written notice terminating the Robles lease unless petitioners executed the new lease. Because the Robles lease was month-to-month and expressly required written notice to terminate, the June 18, 1987 letter qualified as that notice. The petitioners’ subsequent lump-sum rental payment (March 22, 1991) and DBP’s prior acceptance of some rentals di

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.