Case Summary (G.R. No. L-37976)
Contract Obligations and Breach
The contract specified that Sarangaya must obtain the titles within one year; failure to do so would relieve the vendees of their obligation to purchase. Sarangaya acquired the titles on August 5, 1958, and the vendees were notified the following month. The contract provided that notice served to any of the vendees constituted notice to all. Therefore, by October 11, 1958, the vendees were obligated to either pay the purchase price of ₱116,243 or incur liquidated damages of ₱50,000 if they defaulted, which they did.
Legal Action Initiated
Due to the vendees' default, Sarangaya filed a lawsuit against them on January 12, 1959, claiming liquidated damages and other costs. The court considered the complaint a declaration of rescission of the contract. The vendees failed to respond appropriately—one was declared in default for not answering, while another was improperly declared in default after service of summons through publication. Roman answered the complaint but later failed to appear at the trial.
Court Decisions and Proceedings
On March 30, 1960, the trial court ruled against the vendees, ordering them to pay ₱50,000 in liquidated damages and₱1,000 in attorney's fees. Subsequently, Roman filed a motion for reconsideration, claiming he did not receive notice of the title issuance until served with a summons. His motion suggested that he should be granted time to fulfill his obligations under Article 1191 of the Civil Code, which allows for a period to comply if justified.
Settlement Attempts
In hearings that followed, Roman proposed to settle by purchasing the property at the original price, which Sarangaya accepted under specific conditions. However, this offer was never formally accepted as a final settlement, and Roman later became uncooperative. The trial court acknowledged that no agreement had been reached and granted Roman the opportunity to comply with his obligations based on prior offers made.
Critical Judicial Findings
On January 9, 1965, the trial court issued an order allowing Roman to pay at the original price alongside certain costs and fees but made critical errors. It relied on an abandoned settlement proposal and failed to specify a fixed period for compliance as required by law. The court also failed to consider that a substantial amount of time had passed since the original obligation became due.
Court of Appeals Ruling
Sarangaya appealed the trial court's order, leading to the Court of Appeals reversing the previous decision on October 26, 1973. It ordered Roman to pay ₱16,666, representing
...continue readingCase Syllabus (G.R. No. L-37976)
Case Background
- The case involves a review of the Decision made by the Court of Appeals regarding a breach of contract and damages case initiated by Pablo M. Sarangaya against the vendees, including Pablo R. Roman.
- The contract in question was a Contract to Sell, executed on December 12, 1957, concerning five parcels of land in Barrio Dolores, Taytay, Rizal, totaling approximately 116,243 square meters.
- Pablo M. Sarangaya served as the Vendor, while the Vendees included Pablo R. Roman, Porfirio Belgica, and Emilio Yangco.
Contractual Obligations
- The contract stipulated that Sarangaya must secure titles to the lands within one year; failure to do so would relieve the vendees from their obligation to purchase.
- The vendees were required to pay the purchase price of P116,243.00 within 60 days of receiving notice of the title issuance.
- In case of non-compliance, the vendees faced joint liability for liquidated damages amounting to P50,000.00.
Title Acquisition and Notification
- Sarangaya secured the titles on August 5, 1958, with Porfirio Belgica receiving notice on August 12, 1958.
- According to the contract, notice to any of the vendees constituted notice to all, establishing their obligation to pay or face liquidated damages by October 11, 1958.
Legal Proceedings Initiated by Sarangaya
- On January 12, 1959, Sarangaya filed a lawsuit for the recovery of liquidated damages due to the vendees' default, includ