Case Summary (G.R. No. 139791)
Factual Background
Eddy Ng Kok Wei expressed his intention to purchase a condominium unit at Valle Verde Terraces through a Letter of Intent to Manila Bankers Life Insurance Corporation on November 29, 1988. Following this, he paid a reservation fee of P50,000.00 on December 5, 1988. By January 16, 1989, he had paid 90% of the purchase price, totaling P729,830.00, leading to the execution of a Contract to Sell. The contract stipulated that the condominium unit was to be "substantially completed and delivered" within fifteen months from February 8, 1989, with a penalty applied in the event of delays.
Delay in Delivery
As the deadline approached, Eddy Ng returned to the Philippines in April 1990. Petitioner communicated that the condominium unit was substantially complete but indicated delays due to various uncontrollable issues. Although a notice was issued for delivery on May 31, 1990, when Ng returned, the unit was uninhabitable. This situation continued through several visits until he formally demanded damages on November 21, 1990, as no action was taken by petitioner to rectify the issues.
Legal Proceedings
Frustrated, Eddy Ng filed a complaint for specific performance and damages in the Regional Trial Court, Makati City, which was docketed as Civil Case No. 90-3440. Eventually, he accepted the unit and occupied it on April 12, 1991, limiting his claim to damages. On December 18, 1992, the trial court ruled in favor of Ng, awarding him damages due to the unreasonable delay in fulfilling the contractual obligation.
Court of Appeals Decision
The Court of Appeals affirmed the trial court's decision on March 26, 1999. Petitioner’s attempt to challenge the trial court’s jurisdiction, based on the assertion that the National Housing Authority (now the Housing and Land Use Regulatory Board or HLURB) had exclusive jurisdiction over such disputes, was met with several considerations.
Jurisdictional Issues
Petitioner argued against the jurisdiction of the trial court, referencing Section 1(c) of Presidential Decree No. 1344. However, the Supreme Court found that despite any lack of jurisdiction, Manila Bankers Life Insurance Corporation's active participation in the proceedings effectively estopped it from subsequently claiming a lack of jurisdiction. The Court highlighted that a party cannot engage in proceedings and accept the favorable judgment while contesting jurisdiction when the outcome is unfavorable.
Findings of Facts
Regarding the claim of no delay by the petitioner, the Supreme Court reiterated its
...continue readingCase Syllabus (G.R. No. 139791)
Case Overview
- The petition for review on certiorari was filed by Manila Bankers Life Insurance Corporation against Eddy Ng Kok Wei.
- The case numbers are G.R. No. 139791, with decisions rendered by the Court of Appeals dated March 26, 1999, and a resolution dated August 5, 1999.
- The primary issue revolves around a contractual obligation concerning the sale of a condominium unit and subsequent claims for damages due to delays in delivery.
Factual Antecedents
- Eddy Ng Kok Wei, a Singaporean businessman, expressed interest in purchasing a condominium unit at Valle Verde Terraces via a Letter of Intent dated November 29, 1988.
- He paid a reservation fee of P50,000.00 on December 5, 1988, and subsequently 90% of the purchase price, amounting to P729,830.00, on January 16, 1989.
- The Contract to Sell executed by Manila Bankers Life Insurance Corporation stipulated that the unit was to be completed and delivered within 15 months from February 8, 1989, with a penalty for delay.
Delay and Attempts to Deliver
- In April 1990, as the deadline approached, petitioner informed the respondent of substantial completion but cited uncontrollable factors that delayed final turnover until May 31, 1990.
- Respondent repeatedly returned to the Philippines to find the unit still uninhabitable due to lack of essential utilities.
- After multiple not