Case Summary (G.R. No. L-46146)
Relevant Agreements
On May 2, 1975, a Memorandum of Agreement was executed between Maris Trading and Marmont Resort, wherein Maris Trading agreed to drill a well and install a water pump for a fee of P40,000. Subsequently, a second Memorandum of Agreement was signed on October 7, 1975, between Maris Trading and Aurora Guiang, with Federico Guiang signing as a witness. This agreement confirmed the drilling of the water source on the land owned by the Guiang spouses.
Initial Complaints and Actions
Marmont Resort later encountered inadequate water supply and sought to engage a second contractor to improve the system. When attempts to gain access to the existing facilities for inspection and potential repair were denied by the Guiangs, Marmont filed a complaint for damages totaling P110,000, which included fees for the original installation and other incurred expenses.
Respondents' Denial and Counterclaims
The Guiang spouses denied knowledge of the initial agreement with Maris Trading and challenged the validity of the second agreement, claiming it was executed without necessary marital consent. They filed a counterclaim for damages of P200,000 against Marmont.
Trial Court Proceedings and Dismissal
During the trial, the court dismissed the complaint, ruling that Aurora Guiang had transferred possessory rights to Maris Trading but that these rights had not been further transferred to Marmont. The trial court also found the necessary evidence regarding the agreements lacking.
Appeal to the Court of Appeals
Marmont Resort appealed the trial court's decision, but the Court of Appeals upheld the dismissal, asserting that neither memorandum could be considered part of the evidence since they were not formally offered during the trial. They noted the absence of proof that Marmont acquired rights from Maris Trading.
Legal Findings on Judicial Admissions
The Supreme Court found that the stipulations agreed upon during the pre-trial conference constituted judicial admissions. According to the Revised Rules of Court, such admissions do not require additional proof. The court concluded that the Guiang spouses were estopped from disputing the existence and admissibility of both agreements since they had acknowledged them during pre-trial.
Discussion of Consent and Validity
The Court addressed the Guiangs' argument regarding the lack of Federico's consent under Articles 165 and 172 of the Civil Code. Federico's signature as a witness implied his consent to the agreement executed by Aurora. The court also held that the land’s status as public land did not preclude t
...continue readingCase Syllabus (G.R. No. L-46146)
Case Background
- This case involves a Petition for Review filed by Marmont Resort Hotel Enterprises, Inc. against Federico and Aurora Guiang, seeking to overturn the Decision of the Court of Appeals dated December 9, 1986.
- The Court of Appeals had affirmed the dismissal of Marmont's complaint by the Regional Trial Court of Olongapo City in Civil Case No. 2896-C.
Parties Involved
- Petitioner: Marmont Resort Hotel Enterprises, Inc. - A corporation engaged in the hotel and resort business located in Olongapo City.
- Respondents: Federico Guiang and Aurora Guiang - Spouses who occupied the land where the water facility for Marmont Resort was installed.
Agreements Overview
First Memorandum of Agreement (May 2, 1975):
- Executed between Maris Trading and Marmont, wherein Maris Trading agreed to drill for water and establish a water supply facility for Marmont.
- Fee stipulated at P40,000.00.
Second Memorandum of Agreement (October 7, 1975):
- Executed between Maris Trading and Aurora Guiang, with Federico Guiang as a witness.
- Stated that Maris Trading had installed a water source on land owned by Aurora Guiang with her permission.
- Aurora sold and ceded all possessory rights over the land to Maris Trading for P1,500.00.
Nature of the Dispute
- Marmont sought to implement additional installations to improve its inadequate water supply but was denied access to the facility by the Guiang spouses.
- Marmont filed a Complaint against the Guiang spouses for damages resulting from this refusal.
Claims and Counterclaims
Marmont's Claims:
- Damages totaling P11