Case Summary (G.R. No. 102657)
Background Facts
The ACA, which owned three parcels of land in Bangkal, Meycauayan, Bulacan, held a public bidding on March 22, 1979, for the sale of the properties. Petitioner Feliciano Nito had been a lessee of a portion of the land but did not participate in the bid bond contribution of P133,000, which involved a group led by Conrado Villarama, representing multiple interested parties. Instead, Nito intended to independently negotiate with ACA regarding the purchase of a specific lot with a preferred frontage, leading to a dispute over his commitment to the group’s agreements.
Negotiation and Agreements
On March 22, 1979, Villarama emerged as the sole bidder at the auction. Following this, ACA advised the group to formally appoint Villarama as their representative and to negotiate terms. The group, which included Nito, consolidated contributions and executed a manifesto authorizing Villarama to act on their behalf. Notably, Nito did not sign this manifesto or contribute to the collective bid bond. On September 10, 1979, he made a personal payment of P10,000 to Villarama but did not fulfill the complete payment of P1,600,000 due by March 16, 1982, asserting a disparity in the land’s size.
Petitioner’s Non-Compliance
As the payment deadline approached, Nito was informed by the group's legal counsel, Atty. Irineo Guardiano, of the necessity to pay for his share, which he ignored. When he made a direct payment attempt of P125,000 to ACA on March 17, 1982, it was rejected and he was instructed to deal through Villarama. Nito's lack of attendance at the payment meeting and his refusal to follow through with the group’s decision impeded the purchase process.
Actions Taken by the Group and Petitioner’s Response
On March 16, 1982, citing Nito's absence and non-payment, the group offered the lot designated for him to Candido Milan, who accepted, thus beginning the process of the lot’s reallocation. The group later used Milan’s funds to cover the purchase price and successfully completed the transaction. Nito's unsuccessful attempt to assert ownership led him to file a complaint for reconveyance of the property, claiming breaches of trust.
Court Findings and Rulings
The Regional Trial Court dismissed Nito’s complaint, affirming that he had no legal basis to claim a portion of the property since he did not substantively participate in the agreement or pay his share. The court found no evidence of a binding agreement to which Nito could claim co-ownership under Article 1452 of the Civil Code. The conditions for establishing a trust were not satisfied as Nito’s prior objections to the group’s allocation undercut his standing
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Background of the Case
- The case involves an appeal by Feliciano Nito against the decision of the Court of Appeals, which affirmed the Regional Trial Court's dismissal of Nito's complaint.
- The former Agricultural Credit Administration (ACA), now known as the Land Bank, owned three parcels of land in Bangkal, Meycauayan, Bulacan, which were put up for public bidding.
- Nito previously leased a portion of the land but did not participate or contribute to the bid bond for the public bidding organized by ACA.
Formation of the Bidding Group
- A group of interested parties, including Conrado Villarama, formed an alliance to participate in the bidding and appointed Villarama as their representative.
- Each member contributed to a total bid bond of P133,000.00, but Nito did not contribute, despite being included in the group due to his occupancy.
Bidding Process and Agreements
- On March 22, 1979, Villarama was the sole bidder and was directed to negotiate directly with ACA.
- The group formalized their agreement through a manifesto, authorizing Villarama to negotiate for the purchase of the property. Nito did not sign this manifesto.
- Nito provided Villarama with a cash deposit of P10,000.00 on September 10, 1979, but did not pay the full amount required for his share.
Non-Payment and Subsequent Actions
- Nito was informed by the group's counsel, Atty. Irineo Guardiano, about his obligat