Case Summary (G.R. No. 130864)
Relevant Facts
In January 1993, Harold paid Aliba PHP 4,050 for his services. However, Aliba failed to return the property titles for over a year despite multiple demands. In January 1994, Aliba persuaded Harold and her husband to sign a document, claiming it was necessary for the consolidation-subdivision. Subsequently, they discovered that he had sold the property to a third party and offered Harold various amounts as a purchase price without her consent.
Barangay Conciliation Proceedings
The dispute was referred to the local barangay officials for mediation, where on June 8, 1994, both parties agreed to an additional payment of PHP 75,000 on top of PHP 500,000 already proposed by Aliba. Harold accepted PHP 70,000 during the proceedings, documented by an acknowledgment receipt signed by the parties and witnessed by barangay officials. The following day, Aliba attempted to tender the remaining PHP 5,000, which Harold refused, insisting the amount was insufficient.
Court Proceedings and Dismissal
The Municipal Trial Court (MTC) dismissed Harold's complaint on September 4, 1995, based on findings of a valid amicable settlement having occurred during the barangay proceedings. It indicated that Harold had effectively waived her claims against Aliba by accepting the PHP 70,000. Harold then appealed to higher courts, but both the Regional Trial Court (RTC) and the Court of Appeals affirmed the MTC's dismissal, citing substantial compliance with legal requirements for amicable settlements.
Legal Considerations and Findings
The central legal issue revolved around whether there was a valid amicable settlement between the parties, and if Harold’s refusal to accept the remaining payment constituted a repudiation of that settlement. The courts held that significant evidence pointed to a consensual agreement during the hearings, fulfilling the amicable settlement criteria under the Local Government Code.
Doctrine of Estoppel
The ruling articulated the principle of estoppel, asserting that Harold’s previous acceptance of pa
...continue readingCase Syllabus (G.R. No. 130864)
Case Information
- Court: Supreme Court of the Philippines
- Decision Date: October 02, 2007
- G.R. No.: 130864
- Division: Second Division
- Petitioner: Maria L. Harold
- Respondent: Agapito T. Aliba
Background of the Case
- Maria L. Harold engaged Agapito T. Aliba, a geodetic engineer, in January 1993 for a relocation survey and consolidation-subdivision of properties, including those belonging to her sister, Alice Laruan.
- Aliba was compensated with a fee of P 4,050 for his services but failed to return the certificates of title for over a year despite numerous requests.
- In January 1994, Aliba convinced Harold and her husband to sign a document purportedly necessary for the consolidation-subdivision, which they did without reading.
- On April 18, 1994, Harold discovered that Aliba had sold their lot to a third party, subsequently offering Harold various amounts as a purchase price for the land.
Events Leading to Litigation
- Harold initially agreed to accept P 500,000 as partial payment for the lot but later learned Aliba misrepresented the sale price and had her titles cancelled and transferred.
- A series of barangay conciliation meetings were held, culminating in an agreement for Aliba to pay an additional P 75,000 on top of the initial P 500,000 already paid.
- During the proceedings on June 8, 1994, Aliba paid P 70,000, which Harold accepted. The remaining P 5,000 was offered the next day, but Harold refused, insisting that the total was inadequate.
Court Proceedings
- Harold’s complaint against Aliba was dismissed by the Munici