Case Summary (G.R. No. 181664)
Applicable Law
The case arises within the context of the 1987 Philippine Constitution and pertinent laws regarding contracts, property rights, and jurisdictional procedures as outlined in the 1997 Rules of Civil Procedure.
Background of the Case
In January 2000, DPWH entered into a contract of sale with Crispin D. Ramos for a portion of land necessary for the construction of the New Gayaman Bridge. The deed recognized Ramos as the sole vendee despite the property being co-owned, which included his sibling, Jose Advito D. Ramos. A payment of P570,000.00 was made by DPWH to Land Bank, with Ramos withdrawing an initial amount of P100,000.00. However, following a dispute regarding the rightful owners of the property and the corresponding distribution of the proceeds among heirs, DPWH requested that Land Bank suspend further payments pending legal clarification.
Legal Proceedings
Crispin D. Ramos subsequently filed a complaint for recovery of bank deposits with damages against Land Bank, its branch manager, and a field attorney, asserting his right to the remaining payment. In response, Land Bank contended that it was bound by DPWH's request and that no release of funds could occur without a clear resolution regarding the ownership of the property, leading to a third-party complaint against DPWH.
Trial Court Decision
The Regional Trial Court (RTC) ruled in favor of Ramos, ordering Land Bank to release his deposit along with litigation and attorney's fees. Land Bank's motion for reconsideration was denied, and DPWH withdrew its appeal against the RTC's ruling.
Court of Appeals
Land Bank's appeal to the Court of Appeals was ultimately dismissed for lack of jurisdiction, as the court determined it involved only questions of law. The appellate court identified that no factual disputes existed; instead, the case revolved around the legal interpretations of the earlier court’s conclusions.
Supreme Court Ruling
In reviewing the Court of Appeals' dismissal, the Supreme Court found it erroneous. It determined that Land Bank's appeal raised mixed questions of law and fact, as it addressed both the application of law regarding agency relationships between DPWH and Land Bank, and the factual basis of damages awarded to Ramos. The Supreme Court emphasized that questions of fact and law could not be simplified into pure legal inquiries when they warranted factual consideration for decisions, including the justification of attorney's fees.
Conclusion and Remand
The Supreme Court granted the petition for review, set aside the appellate court’s re
Case Syllabus (G.R. No. 181664)
Case Overview
- The case revolves around a petition for review on certiorari filed by the Land Bank of the Philippines (petitioner) seeking to reverse a Resolution issued by the Court of Appeals (CA) which dismissed the appeal for lack of jurisdiction.
- The case originated from a contract of sale between the Department of Public Works and Highways (DPWH) and respondent Crispin D. Ramos concerning a land affected by the construction of a bridge.
Background of the Case
- In January 2000, DPWH entered into a contract of sale for a portion of land, co-owned by several heirs including respondent Ramos, for the construction of the New Gayaman Bridge in Binmaley, Pangasinan.
- Crispin D. Ramos was identified as the sole vendee in the Deed of Absolute Sale, despite the property being co-owned by the heirs of the late Mariano Diaz.
- The agreed purchase price was P570,000.00, which DPWH paid to Ramos through an account at Land Bank.
Events Leading to the Dispute
- After a partial withdrawal by Ramos, DPWH issued a letter requesting Land Bank to withhold further payment due to a claim from Ramos's brother, asserting that he too was entitled to a share of the proceeds from the sale.
- DPWH's legal services director recommended holding the payment until the heirs reached a part