Case Summary (G.R. No. 125986)
Factual Background
The case revolves around a property located in Sucat, Muntinlupa, co-owned by petitioner Aida M. Posadas and her two minor children. In a bid to develop this 1.6-hectare land into a residential subdivision, Posadas entered into negotiations with Jaime T. Bravo, a representative of James Builder Construction. On May 3, 1989, Posadas granted Bravo authorization to negotiate for the removal of squatters occupying the lot. Subsequently, on December 11, 1989, she transferred the property to Luxuria Homes, Inc. through a Deed of Assignment, with Bravo as a witness.
Dispute Arises
By 1992, the relationship between Posadas and Bravo deteriorated due to disagreements over management contracts related to the development. Bravo claimed he was owed P1,708,489.00 for services rendered, which included relocation of squatters and preparation of necessary architectural plans. When Posadas refused to settle the account, Bravo and his company filed a complaint for specific performance against both Posadas and Luxuria Homes, Inc.
Trial Court Proceedings
The trial court declared Posadas in default on September 27, 1993, granting private respondents the opportunity to present their evidence without contest. On March 8, 1994, the trial court ordered Posadas and Luxuria Homes to pay damages of P1,708,489.00 plus additional amounts for other incurred expenses, totaling P1,500,000.00 for actual damages, and P500,000.00 for moral and exemplary damages.
Court of Appeals Decision
The petitioners appealed the decision, and the Court of Appeals affirmed the trial court's ruling but modified the award, deleting the moral damages on the basis that a corporation cannot experience such damages, and reducing the exemplary damages to P50,000.00.
Review and Reconsideration
The Supreme Court initially denied the petition for review but later reinstated it after a motion for reconsideration was filed. The Court highlighted that for damages claimed, the awards must not exceed what was specifically sought in the original complaint.
Burden of Proof and Evidence
The Supreme Court examined whether the private respondents provided sufficient evidence to substantiate their claims. It determined that while Posadas did authorize Bravo for certain services, the evidence presented was insufficient to prove the completion of all tasks claimed, particularly regarding the alleged services related to squatter relocations and fencing.
Liability of Luxuria Homes, Inc.
The Court also addressed whether Luxuria Homes, Inc. could be held liable for Posadas' obligations. It concluded that private respondents f
...continue readingCase Syllabus (G.R. No. 125986)
Case Background and Factual Context
- Petitioner Aida M. Posadas and her two minor children co-owned a 1.6-hectare property in Sucat, Muntinlupa, occupied by squatters.
- Petitioner Posadas engaged respondent Jaime T. Bravo to negotiate with squatters in May 1989 to have them vacate the property, authorizing him in writing.
- In December 1989, Posadas and her children assigned the property to Luxuria Homes, Inc., which she formed purportedly for organizational and tax avoidance reasons.
- Respondent Bravo witnessed the Deed of Assignment and Articles of Incorporation of Luxuria Homes.
- By 1992, relations between Posadas and Bravo deteriorated due to disagreements over proposed management contracts for the development of the subdivision.
- Respondent Bravo demanded payment for services rendered related to relocating squatters, architectural design, site development, and other preparations totaling P1,708,489.00.
- Posadas refused payment, leading to a complaint filed by respondents before the Regional Trial Court for specific performance and various damages.
Legal Proceedings and Trial Court's Decision
- Posadas was declared in default; respondents presented their evidence ex-parte.
- The trial court awarded respondents:
- P1,708,489.00 for services rendered concerning the 1.6-hectare property.
- Actual damages of P1,500,000.00 for construction of warehouse, bunkhouse, hollow block factory, materials, and guards.
- Moral and exemplary damages of P500,000.00.
- Attorney's fees of P50,000.00 plus other costs.
- Ordered Posadas to execute the management contract she had committed to.
Court of Appeals' Ruling and Modifications
- Affirmed the trial court's judgment with modifications:
- Deleted the award of moral damages, reasoning that a corporation cannot suffer physical suffering or mental anguish.
- Reduced exemplary damages to P50,000.00.
Supreme Court Review and Issues Presented
- Summary of issues:
- Whether respondents presented sufficient ex-parte evidence to substantiate their claims.
- Whether Luxuria Homes, Inc. can be held