Case Summary (G.R. No. 144661)
Relevant Dates
The dispute traces its origin to a written offer made by Francisco Ong on May 25, 1988, followed by further communications and offers exchanged between the parties, culminating in an initial trial court decision on April 25, 1995, which the lower court later reversed on September 26, 1996. The decisions from the Court of Appeals under CA-G.R. CV No. 54919 were rendered on March 5, 1999, and the subsequent resolution occurred on July 19, 2000.
Applicable Law
The legal analysis is based on the 1987 Philippine Constitution, specifically focusing on the laws governing contractual agreements, parol evidence, and the implications of corporate representation in binding transactions.
Facts of the Case
The controversy began when Francisco Ong, with the consent of his wife Leticia, submitted a formal offer to purchase the subject property for P136,000. The offer included specific conditions regarding down payments and potential competition from third-party buyers. The offer was acknowledged by DBP’s branch manager, which led the Ongs to believe that their offer was likely accepted. However, when DBP later decided to pursue a public bidding process for the same property, the Ongs claimed this constituted a breach of contract, prompting them to file a complaint for specific performance against the bank.
Trial Court Proceedings
Initially, the trial court ruled on April 25, 1995, that there was no perfected contract between the parties, thereby dismissing the Ongs' complaint. However, upon the respondents' motion for reconsideration, the trial court reversed its ruling on September 26, 1996, finding in favor of the Ongs and determining that a contract of sale had indeed been perfected. This decision was based on evidence presented, chiefly the Ongs’ testimony regarding their interactions with DBP staff and the work of a bank clerk who facilitated their offer.
Court of Appeals’ Findings
The Court of Appeals upheld the trial court's decision on March 5, 1999, affirming that the testimony of Francisco Ong, coupled with the failure of DBP to present any rebuttal evidence from its staff, constituted sufficient proof of a perfected contract. The appellate court also emphasized the importance of the representations made by bank personnel, binding the DBP to the agreement reached.
Issues on Appeal
DBP challenged the appellate court's ruling on several grounds, notably claiming that the introduction of parol evidence to prove the existence of a meeting of minds was inappropriate given there was no formal executed contract. It argued that the burden of proof lay with the Ongs to substantiate the existence of a perfected sale agreement. There were also claims regarding the inadmissibility of the evidence presented by the Ongs due to lack of corroborating witnesses.
Supreme Court Ruling
In evaluating the appeal, the Supreme Court granted the petition filed by DBP, reversing the decisions of the lower courts. The Court concluded that without a perfected contract of sale, there was no basis for the Ongs' claims of breach of contract or specific performance. The Supreme Court highlighted that DBP’s mere acknowledgment of the Ongs' offer did not equate to a formal or binding acceptanc
...continue readingCase Syllabus (G.R. No. 144661)
Case Background
- The case arises from a petition for review on certiorari involving the Development Bank of the Philippines (DBP) as the petitioner and Spouses Francisco Ong and Leticia Ong as respondents.
- The appeal is against the Decision dated March 5, 1999, and the Resolution dated July 19, 2000, of the Court of Appeals in CA-G.R. CV No. 54919.
- The matter pertains to a suit for breach of contract and/or specific performance initiated by the respondents against DBP.
Factual Context
- The dispute revolves around a foreclosed property previously owned by Enrique Abada, located at Corrales Extension, Cagayan de Oro City.
- Respondent Francisco Ong submitted a written offer to purchase the property on May 25, 1988, with a purchase price of P136,000, a downpayment of P14,000, and a balance of P122,000, to be paid upon the ejection of occupants.
- The offer contained a clause stipulating that it would not bind DBP until approved by higher authorities.
Offer and Acceptance Dynamics
- The initial offer was acknowledged by DBP’s branch manager, Jose Z. Lagrito, who issued an official receipt for the downpayment.
- A letter dated October 21, 1988, informed the respondents of a competing offer from another buyer, providing them three days to match the offer.
- The respondents matched the offer on October 28, 1988, assuming responsibility for ejecting any occupants.
Legal Proceedings
- The trial court initially dismissed the complaint on April 25, 1995, ruling that there was no perfected contract of sale; however, upon