Case Summary (G.R. No. 124452)
Background of the Case
The case began when Conchita A. Sonley filed a Complaint on March 13, 2009, in the Regional Trial Court against Anchor Savings Bank, seeking a declaration of nullity regarding the rescission of a contract and demanding damages. Sonley claimed that she had agreed to purchase a property in Fairview, Quezon City, for Php2,200,000, paying an initial downpayment of Php200,000 and committing to monthly installments. However, due to her defaults on these payments, Anchor rescinded the contract, leading to the dispute.
First Instance Ruling
The trial court, following an amicable settlement that resulted in a Compromise Agreement, issued a judgment on August 16, 2010. This judgment required Sonley to repurchase the property, amounting to approximately Php1,469,460.66 plus 12% interest per annum. Subsequently, Anchor filed a motion for execution, asserting that Sonley had failed to comply with payment schedules and that her checks for monthly installments had been dishonored.
Orders and Appeals
On September 8, 2011, the trial court granted the motion for execution, concluding that Sonley had not fulfilled her obligations under the Compromise Agreement. Sonley subsequently filed a Petition for Certiorari with the Court of Appeals, arguing that the trial court had committed grave abuse of discretion by issuing a writ of execution without a legal basis in the judgment.
Ruling of the Court of Appeals
The Court of Appeals determined that the trial court's issuance of a writ of execution was justified. It reasoned that a compromise agreement, once court-approved, holds the same effect as a final judgment and is enforceable. The appellate court emphasized that the terms of the compromise expressly allowed for rescission as a consequence of default in payment. Thus, it affirmed the trial court's order, underscoring the enforceability of compromise agreements under Article 2041 of the Civil Code.
Arguments Presented
In her petition, Sonley contended that the trial court lacked authority to issue a writ of execution without a specific provision for such in the August 16, 2010 judgment. She stated that the remedies available to Anchor included only penalties or the option to rescind the agreement, which should entail a separate judicial action. The respondent, conversely, argued that the default on Sonley's part necessitated rescission, thereby justifying the execution of the judgment.
Supreme Court's Ruling
The Supreme Court upheld the decisions of the lower courts, finding no grave abuse of discretion. It clarified that, per the principles l
...continue readingCase Syllabus (G.R. No. 124452)
Background of the Case
- The case revolves around a Petition for Review on Certiorari filed by Conchita A. Sonley challenging the Court of Appeals' decisions dated August 28, 2012, and January 25, 2013, which denied her Urgent Motion for Reconsideration in CA-G.R. SP No. 122409.
- The dispute originated from a Complaint filed by Sonley on March 13, 2009, for the declaration of nullity of rescission of contract and damages against Anchor Savings Bank (later changed to Equicom Savings Bank).
Factual Antecedents
- Sonley entered into a Contract to Sell with Anchor on January 28, 2005, to purchase a parcel of land in Fairview, Quezon City, for Php2,200,000.00.
- She paid a downpayment of Php200,000.00, with the remaining balance to be paid in monthly installments of Php47,580.00 over 60 months.
- Sonley defaulted on her monthly payments, prompting Anchor to rescind the contract.
- Sonley argued that the rescission was invalid as she had substantially paid her obligations.
Trial Court Proceedings
- Anchor denied Sonley’s claims and asserted that her post-dated checks for the monthly installments were dishonored.
- The parties later reached an amicable settlement resulting in a Compromise Agreement, where Sonley agreed to repurchase the property for Php1,469,460.66, plus 12% interest per annum.
- Anchor subsequently filed a Manifestation and