Case Summary (G.R. No. 190445)
Applicable Law
The governing legal framework includes provisions from the Civil Code of the Philippines, particularly Articles 1358, 1403(2)(e), 1184, and 1545. The decision references the 1987 Philippine Constitution, given the decision date of September 1996.
Factual Background
The case revolves around a dispute regarding the sale and lease of a parcel of land owned by Encarnacion in Quezon City. The land had been occupied by petitioners Lacanilao and Cadurnigara under lease agreements for years. In 1987, a proposal for sale was initiated by Encarnacion, leading to a verbal agreement in May 1988 for the land's sale at P120,000. However, petitioners failed to pay the amount by the stipulated deadline of June 15, 1988. Following their default, Encarnacion sold the property to the Acebos, who paid P145,000 and received a Deed of Absolute Sale.
Legal Proceedings and Trial Court Decision
After the sale to the Acebos, petitioners filed a complaint to annul the deed of sale and to compel Encarnacion to execute a sale in their favor. The trial court dismissed the complaint, concluding that petitioners had not established the existence of an enforceable contract to sell. The court indicated that only parole evidence had been offered, failing to meet the requirements for a written contract as mandated by Article 1403 of the Civil Code.
Court of Appeals Ruling
The Court of Appeals upheld the trial court's decision but modified certain aspects pertaining to damages and attorney's fees. The appellate court determined that the issues raised by the petitioners were largely factual and thus not suitable for review under Rule 45 of the Rules of Court, which restricts petitions to questions of law.
Petitioners' Arguments
In their petition, petitioners contended that the Acebos acted in bad faith by purchasing the property despite being aware of the petitioners' interests. They also argued that their failure to pay the purchase price should not preclude the enforceability of the contract, as it was contingent upon the seller's agreement.
Findings on Legal Principles
The Supreme Court reiterated that a sale agreement contingent on full payment is classified as a contract to sell, where ownership remains with the seller until complete payment is made. The failure of the petitioners to fulfill the payment condition constituted grounds for Encarnacion to terminate the oral agreement. Additionally, the Court noted petitioners' inability to
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Case Reference
- G.R. No. 121200
- Date of Decision: September 26, 1996
- Court: Supreme Court of the Philippines
- Division: First Division
Parties Involved
- Petitioners: Gloria A. Samedra Lacanilao and Plutarco Cadurnigara
- Respondents: Court of Appeals, Eusebio C. Encarnacion, Spouses Ramon and Teresita A. Acebo
Procedural History
- This case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- The decision being reviewed originated from the Court of Appeals in CA-G.R. CV No. 22952 dated July 24, 1995, which affirmed, with modifications, the trial court's ruling dismissing the petitioners' complaint for lack of merit.
Factual Background
- Eusebio C. Encarnacion owned a 160-square meter parcel of residential land in Quezon City.
- In the 1950s, Deogracia la Torre constructed a house on a 100-square meter portion of the lot with Encarnacion's consent.
- The house was subsequently purchased by Gloria A. S. Lacanilao and her common-law husband, Pablo, who resided there.
- On September 12, 1963, Pablo Lacanilao and Encarnacion entered a lease agreement for the 100-square meter portion at a monthly rental of P24.00.
- Encarnacion also leased the remaining 60 square meters to Plutarco Cadurnigara.
- Both petitioners maintained possession of the property and consistently paid rent until November 1988.
- In November 1987, Encarnacion offered to sell the entire lot to the petitioners for P120,000.00.
- After negotiations, Encarnacion agreed to extend the dead