Case Summary (G.R. No. 174826)
Nature of the Appeal
Cornejo filed a direct appeal to the Supreme Court, wherein he sought resolution on specific questions of law only, as stipulated by the appellate procedure. Consequently, the findings of fact by the trial court are accepted as established and are pertinent to the legal determinations subsequently addressed.
Essential Facts and Transactions
In January 1945, Calupitan authorized real estate brokers D.B. Castaneda and Eustacio Barrera to sell his land. Cornejo submitted an offer to purchase the land for P650,000, including an earnest money of P70,000. On the same day, Calupitan accepted the offer. However, Cornejo later revised the terms, paying only P65,000 as earnest money and extending the payment deadline for the remaining P585,000. Calupitan modified the acceptance by indicating that the balance was to be paid in genuine Philippine currency rather than Japanese military notes, which led to the dispute regarding the interpretation of currency.
Court’s Findings on the Agreement
The trial court concluded that Cornejo's reduction of the earnest money and the extension of the payment term constituted a repudiation of the original agreement. Given the volatile circumstances in January 1945, where the value of the Japanese military notes was rapidly diminishing, the court held that time was of the essence in the transaction, and Cornejo's changes to the payment conditions terminated the original pact.
Definition of Philippine Currency
A pivotal issue in the case was the interpretation of "Philippine currency" as used by Calupitan. The trial court established that when Calupitan referred to the balance being paid in Philippine currency, he specified genuine Philippine currency, not Japanese military notes, thus demonstrating that there was no mutual agreement on the new terms proposed by Cornejo.
Lack of Meeting of Minds
The appellate court reaffirmed the trial court's finding that a significant modification to the original agreement rendered it null and void. Because Cornejo's new terms were not accepted by Calupitan, there was no valid contract in place to compel specific performance. Calupitan's insistence on genuine currency was acknowledged through numerous testimonies, especially under the rapidly changing market conditions that influenced his change of terms for the sale.
Judicial Conclusion
Ultimately, the Supreme Court ruled that the original contract was abandoned due to Cornejo's actions, invalidating his claim for specific performance regarding the property. However, the
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Case Overview
- This case involves an appeal from Silverio Q. Cornejo against the judgment of the Court of First Instance of Manila, which absolved the defendants from a complaint for specific performance regarding a real estate transaction.
- The primary legal issue is whether Cornejo is entitled to compel Calupitan to convey a parcel of land after a series of modifications to the original agreement were made.
Background Facts
- In January 1945, Manuel B. Calupitan owned a 110.912-hectare parcel of land in Candelaria, Tayabas, which he authorized brokers D.B. Castaneda and Eustacio Barrera to sell.
- Cornejo offered to buy the land for ₱650,000, with an earnest money deposit of ₱70,000, which Calupitan accepted on January 4, 1945.
- Due to financial constraints, Cornejo only delivered ₱65,000 in Japanese military notes to the brokers on January 6, 1945, and proposed to pay the remaining ₱585,000 by January 25, 1945.
- This new proposition was documented in a receipt (Exhibit C), but Calupitan responded with a receipt that specified the balance be paid in genuine Philippine currency, not in Japanese military notes.
Legal Proceedings
- Cornejo claimed he was unable to deliver the balance due to Calupitan avoiding him, while Calupitan asserted he avoided disclosing his address for security reasons related to his guerrilla activities.
- Cornejo deposited the balance of ₱585,000 with the Clerk of Cou