Case Summary (G.R. No. 120724-25)
Background of the Case
The case involves a petition for review filed by Fernando T. Mate, who contests the Decision of the Court of Appeals dated August 29, 1994. This decision affirmed, with modification, the ruling of the Regional Trial Court concerning a Deed of Sale with Right to Repurchase executed on October 6, 1986 between Mate and Inocencio Tan involving three lots in Tacloban City. The trial court had determined the deed valid and binding, ruled that the redemption period had lapsed, and ordered the consolidation of ownership in favor of Tan.
Facts of the Case
Josefina R. Rey approached Mate to solicit his assistance in averting legal action by Tan related to dishonored checks she issued. Although initially resistant, Mate ultimately agreed to a fictitious deed of sale with a repurchase option, under specific terms, including a stated sale price and condition for repurchase with postdated checks. The checks, however, were later dishonored due to insufficient funds in Rey's account, leading Mate to pursue criminal charges against Rey and a civil case against Tan.
Legal Issues Presented
Mate's primary argument centers on the validity of the Deed of Sale with Right to Repurchase, which he claims is null and void for lack of consideration. He asserts that no actual payment was made since the checks he received were not honored.
Consideration and Contract Validity
The Court of Appeals found that valid consideration existed at the time of the deed’s execution. The court noted that although the checks were dishonored, the act of issuing them and the associated terms established a contractual obligation. The court highlighted that Mate benefited from the arrangement by accommodating Rey, who sought to avoid criminal liabilities, which ultimately prompted his contractual engagement.
Implications of Dishonored Checks
Mate contended that the dishonored checks negated any consideration for the contract. However, the court disagreed, noting that the checks represented Rey’s commitment to fulfill the terms of the sale, even if they were not honored. The dishonor of the checks did not dissolve the underlying contract, emphasizing that Mate, being a lawyer, should have been aware of the inherent risks.
Petitioner’s Misfortunes
The ruling underscored that the blame for the predicament lies with Mate, who voluntarily engaged in the contract despite recognizing the risks involved. The court asserted that the agreement was lawful and binding, and it adhered to the requisite elements of a valid contract. Mate's strategic decisions, including his choice to file criminal charges against Rey rather than repurchase the properties directly, further indicated his awareness o
...continue readingCase Syllabus (G.R. No. 120724-25)
Case Background
- The case involves a petition for review filed by Fernando T. Mate against the Decision of the Court of Appeals dated August 29, 1994.
- The Court of Appeals affirmed with modification a decision from the Regional Trial Court regarding the validity of a Deed of Sale with Right to Repurchase executed on October 6, 1986.
- The trial court ruled that the Deed of Sale was valid and binding, leading to the consolidation of ownership of the properties by Inocencio Tan after the period for redemption expired.
Facts of the Case
- On October 6, 1986, Josefina R. Rey (referred to as "Josie") solicited the help of Mate to avoid prosecution for rubber checks issued to Tan totaling P4,432,067.00.
- Mate initially refused but ultimately agreed to execute a simulated deed of sale with right to repurchase under specific conditions, including:
- Sale price stated as P1,400,000.00 with 5% monthly interest.
- Properties to be repurchased within six months.
- Josie would provide the funds for the redemption.
- Titles would be delivered to Tan but the sale would not be registered.
- Josie issued two postdated checks to Mate as assurance for the redemption: one for the sale price and another for interest.
- Both checks were dishonored due to being