Case Summary (G.R. No. 85723)
Factual Background
In January 1989, Romulo Pascual entered a sale agreement with the respondents concerning three parcels of land in Navotas City. The transaction was documented in a document titled "Pagpapatunay at Pananagutan," affirming Pascual's ownership of the properties. The agreement established a selling price of P350.00 per square meter with a down payment of P50,000.00. Subsequent claims arose regarding whether the titles were registered under the respondents’ names and the issue of payment for the properties.
Procedural History
On October 28, 1993, one of the three lots was registered under the respondents' names. However, Teresita Pascual later asserted that her husband, Romulo, had yet to receive full payment for the properties, leading her to file a complaint for rescission against the respondents in March 2006. The respondents countered that they were not liable for the remaining balance of the purchase price due to Pascual's failure to register the titles in their names as initially agreed.
Ruling of the Regional Trial Court
After trial, the RTC ruled in favor of the respondents, concluding that paragraph 5 of the "Pagpapatunay at Pananagutan" was ambiguous but indicated that titles should be registered in the respondents' names before they were obligated to pay the balance. The court also rejected Pascual's claim for an increase in the purchase price, determining that the agreed amount was binding and enforceable.
Ruling of the Court of Appeals
On appeal, the CA affirmed the RTC's findings, emphasizing that the respondents fulfilled their obligations by making a down payment and that the title transfer was a prerequisite for further payment. The CA highlighted that Pascual failed to fulfill her contractual obligations, and thus could not seek rescission of the agreement.
Issues on Appeal
The petitioner raised several issues regarding the Court of Appeals' interpretation of the parties' intentions during the contract execution, the basis of non-payment for the purchase price, and the reciprocal obligations concerning the transfer of title and payment.
Supreme Court's Ruling
The Supreme Court rejected the petition, reiterating the principle that it does not function as a trier of facts and upholds the factual findings of lower courts unless certain exceptions are met, which were
...continue readingCase Syllabus (G.R. No. 85723)
Case Overview
- This case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
- The petition challenges the Decision dated July 4, 2017, and the Resolution dated November 22, 2017, of the Court of Appeals (CA) regarding the sale of three parcels of land.
- The main parties involved are Teresita E. Pascual, the petitioner, and Encarnacion Pangyarihan-Aang, et al., the respondents.
Factual Background
- In January 1989, Romulo Pascual entered into a sale transaction with Encarnacion P. Ang and her family regarding three parcels of land in Navotas City.
- The transaction was documented in a statement titled "Pagpapatunay at Pananagutan," which detailed the ownership and sale terms.
- The sale was agreed upon at a price of P350.00 per square meter, with an initial payment of P50,000.00 received by Romulo Pascual.
Registration of Property
- On October 28, 1993, one of the parcels of land was registered under the respondents' names.
- The petitioner asserted that the remaining two parcels had titles issued in her late husband's name and claimed that the respondents failed to pay the full purchase price.
- Subsequently, on March 2, 2006, Pascual filed a complaint for rescission of the sale agreement due to non-payment and sought damages.