Title
Pleasantville Development Corp. vs. Court of Appeals
Case
G.R. No. 79688
Decision Date
Feb 1, 1996
Eldred Jardinico sued Wilson Kee for occupying Lot 9 due to CTTEI’s error. SC ruled Kee as a builder in good faith, holding PDC and CTTEI liable for negligence, awarding attorney’s fees to Jardinico.
A

Case Summary (G.R. No. 79688)

Petitioner

  • Pleasantville Development Corporation, owner and developer of Pleasantville Subdivision; principal of CTTEI, its exclusive real estate agent responsible for lot relocation and delivery.

Respondents

  • Wilson Kee: contracted to buy Lot 8, took possession after CTTEI’s pointing-out, constructed residence and commercial improvements on the lot wrongly identified as Lot 8 (in fact Lot 9).
  • C.T. Torres Enterprises, Inc. (CTTEI): petitioner’s agent that prepared lot plan and accompanied Kee’s wife to inspect the lot; employee Octaviano pointed to Lot 9 in error.
  • Eldred Jardinico: bought Lot 9 from Edith Robillo, later registered under TCT No. 106367 and sued Kee for ejectment and damages.

Key Dates and Transactions

  • March 26, 1974: Kee bought on installment Lot 8 from CTTEI.
  • January 20 & 27, 1975: Kee paid relocation and lot plan fees to CTTEI.
  • December 19, 1978: Jardinico secured TCT No. 106367 for Lot 9.
  • March 12, 1981: Jardinico filed ejectment suit against Kee.
  • July 24, 1987: Kee and Jardinico executed a deed of sale wherein Jardinico sold Lot 9 to Kee; they agreed the litigation between them would be disregarded.
  • Decision under review and final disposition occurred after 1990; therefore the 1987 Constitution is the governing constitutional framework for the Court’s exercise of jurisdiction.

Applicable Law and Authorities Cited

  • Civil Code provisions relevant to rights and remedies of builders and owners: Articles 448, 526–528 (presumptions and builders’ rights), 546, 548.
  • Agency and principal liability: Articles 1897, 1909, 1910 (Civil Code).
  • Waiver and public policy: Article 6 (Civil Code).
  • Damages and costs: Article 2208 (Civil Code) and court discretion on attorney’s fees (cited precedents).

Facts Found by the Courts

  • Kee paid for lot relocation and received a lot plan; CTTEI’s employee Octaviano accompanied Kee’s wife to identify the lot but erroneously pointed to Lot 9. Kee then constructed multiple improvements on the lot subsequently revealed to be Lot 9, owned by Jardinico.
  • MTCC found CTTEI responsible for the erroneous delivery, held Kee had no right after contract rescission, ordered ejectment, removal of improvements, rentals, and awarded attorney’s fees to Jardinico.
  • RTC reversed the finding of CTTEI/petitioner’s fault, found Kee a builder in bad faith and liable for rentals from the date of demand, and dismissed third-party claims against petitioner/CTTEI.
  • Court of Appeals reversed the RTC, declared Kee a builder in good faith, imputed CTTEI’s negligence to petitioner, awarded Kee rights under Articles 448, 546 and 548, ordered petitioner and CTTEI solidarily liable under specified circumstances (demolition or sale), reinstated attorney’s fees, and remanded for valuation of improvements and land.

Issues Presented

  1. Whether Kee was a builder in good faith when he constructed improvements on Lot 9.
  2. Whether petitioner Pleasantville Development Corporation (and CTTEI as its agent) is liable for CTTEI’s erroneous pointing-out/delivery.
  3. Whether the award of attorney’s fees to Jardinico is proper.

Analysis — Builder in Good Faith

  • Legal standard: Good faith of a builder consists in his belief that the land he is building upon is his and ignorance of any defect in title; good faith is presumed (Arts. 526–527; precedent Floreza v. Evangelista).
  • Application: Kee took reasonable steps to verify his lot (paid relocation fee, obtained lot plan, and inspected the lot accompanied by CTTEI’s employee who positively identified the lot). Given his lay status regarding technical descriptions and the authoritative identification by CTTEI’s representative, Kee’s reliance was reasonable.
  • Contractual breaches (violations of paragraphs 22 and 26 requiring notice and approval for construction) affect contractual remedies but do not negate the presumption of good faith as to the state of mind at the time improvements were made.
  • Rescission of Kee’s installment contract prior to Jardinico’s complaint affects Kee’s contractual rights but does not disprove that Kee acted in good faith when constructing the improvements.
  • Conclusion: Kee was properly declared a builder in good faith; burden was on petitioner to prove bad faith and it failed to do so.

Analysis — Principal and Agent Liability

  • Governing principle: A principal is liable for acts of its agent done within the scope of authority; an agent exceeding authority may be personally liable, but negligence by an agent acting within authority is imputable to the principal (Arts. 1897, 1909, 1910; Lopez v. Alvendia).
  • Application: CTTEI was the exclusive agent tasked with relocation and lot delivery. The erroneous pointing-out occurred in the course of CTTEI’s authorized duties; while the agent did not exceed the scope of its authority, it acted negligently. That negligence is attributable to Pleasantville as principal.
  • Limits on remedies ordered by Court of Appeals: The Supreme Court found error in the appellate court’s imposition of specific solidary liability forms (i.e., requiring petitioner/CTTEI to pay demolition expenses or the land value to effect ownership transfer), reasoning that the rights and remedies between owner and builder are governed by the Civil Code (Arts. 448, 546, 548) and that the Court of Appeals improperly modified statutory rules under the guise of equity.
  • Procedural posture affecting damages: No proper evidence on the extent or amount of damages was adduced at trial, so petitioner’s liability for damages could not be quantified on the present record. The deed of sale between Jardinico and Kee, executed July 24, 1987, settles the reciprocal rights between those two parties and renders unnecessary the remand for valuation contemplated by the Court of Appeals.
  • Conclusion: Petitioner is liable for damages caused by its agent’s negligence, but the particular remedies and quantification of damages requested by the Court of Appeals were not sustained; items in the appellate disposition imposing specific solidary obligations (demolition costs or land payment) were deleted.

Analysis — Attorney’s Fees

  • Legal rule and discretion: Award of attorney’s fees lies within the court’s discretion and depends on circumstances (cited precedent). Article 2208 provides for recovery of damages including attorney’s fees where appropriate.
  • Application: Because Jardinico was compelled to litigate to protect his rights due to the agent’s negligence, t

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