Case Summary (G.R. No. 129103)
Background of the Case
Daluyong Gabriel owned the subject property, inherited from his father, and appointed his sister, Maria Rita, as the administratrix while he lived in Mandaluyong, Metro Manila. On June 21, 1985, a lease contract was made with Lydia De Los Reyes. Later, this lease was novated on September 26, 1985, to a new contract involving Renato Gabriel. In November 1987, Lydia verbally agreed to buy a total of 300 square meters of land from Daluyong’s estate, for which she made several payments, though no formal sale document was executed.
Dispute and Initial Legal Actions
Conflict arose when Daluyong Gabriel directly objected to the construction of a building by the De Los Reyes couple on the property, leading him to demand they vacate. Daluyong initiated legal action in November 1989 for recovery of possession, while the De Los Reyes couple counterclaimed for specific performance, asserting their right to the property based on the alleged sale by Renato.
Trial Court Decision
The Regional Trial Court admitted the oral sale's validity, ordering the execution of necessary documents to transfer the property to the De Los Reyes couple, highlighting that Daluyong had tacitly authorized Renato to sell the property.
Court of Appeals Ruling
Upon appeal, the Court of Appeals reversed the trial court's decision, deeming the sale invalid on the grounds that Renato lacked the authority to sell as he was not the registered owner of the land nor did he possess authorization from his father, Daluyong. The appellate court further established that as a matter of law, any sale by an unauthorized agent is void ab initio.
Legal Arguments and Considerations
The petitioners argued that despite the lack of formal authority on Renato's part at the time of sale, the subsequent inheritance by him after Daluyong's death validated the sale. The petitioners also contended that by their actions, Daluyong had ratified the sale. The respondents countered that the petitioners' arguments changed during the course of litigation, and stressed Renato's lack of ownership at the time of the claimed sale.
Supreme Court Analysis
The Supreme Court emphasized that consent and capacity are fundamental to the validity of contracts. It upheld the Court of Appeals' ruling that Renato had no authority to sell the land, thereby rendering the contra
...continue readingCase Syllabus (G.R. No. 129103)
Case Background
- Petitioners Claudio Delos Reyes and Lydia Delos Reyes filed a petition for review on certiorari to contest the Decision of the Court of Appeals (CA-G.R. CV No. 36955), which reversed the consolidated Decision of the Regional Trial Court (RTC) in Civil Case Nos. 2326 and 2327.
- The petition was originally filed on June 16, 1997, and after a motion for reconsideration, it was reinstated on December 3, 1997.
- The private respondent, Daluyong Gabriel, passed away on September 14, 1995, and was replaced in the case by his heirs: Renato Gabriel, Maria Luisa B. Esteban, and Maria Rita G. Bartolome.
Facts of the Case
- Daluyong Gabriel was the registered owner of a 5,010 square meter parcel of land in Tagum, Davao del Norte, acquired through hereditary succession in 1974.
- Due to residing in Mandaluyong, his sister Maria Rita Gabriel de Rey acted as the administratrix, collecting rentals from tenants, including Lydia De Los Reyes.
- A lease agreement was executed on June 21, 1985, allowing Lydia to lease 176 square meters for one year, renewable at a rate of P200.00 per month.
- In 1985, the lease was novated, and a new contract was executed on September 26, 1985, with Renato Gabriel as the lessor, extending the lease to six years and acknowledging a total rental payment of P14,400.00.
Sale Agreement
- In November 1987, Lydia de Los Reyes verbally agreed to purchase 300 square meters of the land at P300.00 per square meter, with payments made in installments.
- Despite several receipts acknowledged by Renato Gabriel, no formal dee