Case Summary (G.R. No. 93176)
Background of the Case
On April 28, 1967, the petitioner and Guadalupe Sering entered into a Contract to Sell for a parcel of land. Subsequently, Guadalupe transferred her rights to her spouse, Socorro, who along with Jose, began making the necessary payments. The private respondents experienced multiple defaults in their payments, but the petitioner accepted these late payments on various occasions. Eventually, the petitioner issued a notice of rescission due to defaults but later revoked this notice after the respondents updated their payments under certain conditions.
Procedural History
After further defaults, when Jose Sering attempted to pay the outstanding balance in September 1975, the petitioner’s employee refused to accept the payment, claiming the contract had already been canceled. Following this, the private respondents initiated a legal action for specific performance, which encountered jurisdictional issues leading to administrative proceedings with the Human Settlements Regulatory Commission (HSRC) and later the Office of the President, which ultimately ruled in favor of the private respondents.
Ruling of the Office of the President
The Office of the President concluded that the petitioner had instituted unfair practices by canceling the contract after previously accepting late payments. It noted that there was no solid proof that the respondents received a notice of rescission. The Office enforced equitable principles, stating that it would be unjust for the petitioner to refuse the final payment after having accepted late payments previously.
Legal Issues Raised by the Petitioner
The petitioner raised three main errors: (1) whether the notice of rescission served any legitimate purpose given the lack of confirmed receipt by the private respondents; (2) whether the petitioner was estopped from insisting on the rescission due to the acceptance of delayed payments; and (3) whether the petitioner could refuse the remaining balance payment and deny the execution of the final deed of sale.
Administrative Findings
The findings of the Office of the President, treated as factual, determined that the notice of rescission had not been properly served. It emphasized the principles established in the Maceda Law, insisting that notice is integral to the cancellation process of such contracts, even if the contract predates the law's enactment.
Waiver of Rights and Estoppel
The petitioner contended that acceptance of delayed payments did not constitute a waiver of its rights. However, the ruling highlighted that by repeatedly accepting late payments, the petitioner essentially waived its right to rescind based on these delays. The characteristics of the Contract to Sell indicated that it may be a contract of adhesion, suggesting an imbalance in bargaining power that further reinforced the private respondents' legal position.
Nature of Breach and Impact of
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Case Overview
- This case involves a petition for certiorari under Rule 65 of the Revised Rules of Court.
- The petitioner, Siska Development Corporation, seeks to review, reverse, and set aside Resolution No. 3376 dated November 25, 1988, and the Order dated December 6, 1989, from the Office of the President of the Philippines.
- Resolution No. 3376 reversed the decision of the Human Settlements Regulatory Commission (HSRC), mandating the petitioner to execute a final deed of sale for a disputed lot upon payment of the remaining balance of P9,341.24.
Background of the Case
- On April 28, 1967, the petitioner entered into a Contract to Sell with Guadalupe Sering for a lot in Mira-Nila Subdivision, Quezon City.
- Guadalupe Sering later transferred her rights to her husband, Jose Sering, and wife, Socorro Sering, who then assumed the obligations of the contract.
- Throughout the duration of the contract, the private respondents defaulted on their monthly amortizations but continued to make late payments, which the petitioner accepted.
- On October 18, 1974, the petitioner issued a notice of rescission due to non-payment but later canceled this notice on November 12, 1974, after the respondents made overdue payments.
- The petitioner stipulated that the respondents must keep their payments current, warning that any future rescission would be final.
Legal Actions and Proceedings
- Following another default from January to September 1975, Jose Sering attempted to pay the re