Case Summary (G.R. No. 165168)
Factual Antecedents
The disputed property, Lot No. 263, measures 860 square meters and is covered by Original Certificate of Title No. 0-271 registered under Eugenia T. Primero. Initially, Eugenia leased the lot to Irene for a monthly rental fee of ₱500. An unnotarized agreement dated January 13, 1985, was drawn where Eugenia offered to sell Irene the property at ₱1,000 per square meter. The agreement required a ₱40,000 deposit, part of the down payment, with further stipulations regarding payment timelines. Irene failed to complete the down payment within the specified period but continued to stay on the property and made payments totaling ₱293,000. In 1996, Eugenia and her heirs filed a complaint for unlawful detainer against Irene and Nonilon before the Municipal Trial Court, which ultimately dismissed the case for lack of jurisdiction.
Regional Trial Court Proceedings
Irene and Nonilon subsequently initiated a case for specific performance in the Regional Trial Court, seeking to compel the conveyance of a 293-square meter portion of Lot No. 263. During trial, key testimonies were presented, including that of Irene, who contended that they later entered into an oral contract of sale. In contrast, the respondents presented evidence indicating that Eugenia had no authority to sell the property, particularly because it was conjugal property. The Regional Trial Court decided to dismiss the complaint, ruling that the evidence did not support a contract of sale.
Court of Appeals Proceedings
The petitioners appealed the Regional Trial Court's decision to the Court of Appeals, which affirmed the lower court's ruling. They argued in their petitions whether an oral contract of sale could bind the seller; whether a seller could be compelled to execute a deed of sale; and whether the receipts issued reflected a valid contract of sale. The appellate court maintained that the initial agreement was a contract to sell, not a contract of sale due to the failure of the petitioners to comply with the payment terms.
Legal Analysis and Ruling
The Supreme Court affirmed the decisions of both lower courts, characterizing the January 13, 1985 Agreement as a contract to sell rather than a contract of sale, as ownership was not transferred until full payment was made. Despite arguments made by the petitioners, the Court found that the conditions for sales were not met, as Irene did not fulfill her obligations under the agreement, resulting in the respondents' obligation to convey the property never arising. Moreover, the alleged o
...continue readingCase Syllabus (G.R. No. 165168)
Jurisdictional Overview
- The case was decided by the First Division of the Supreme Court of the Philippines on July 9, 2010, under G.R. No. 165168.
- The core of the dispute revolves around a property transaction involving a disputed contract between the petitioners and the respondents, concerning Lot No. 263 located in Iligan City.
Background and Factual Antecedents
- Lot No. 263, measuring 860 square meters and covered by Original Certificate of Title No. 0-271, was owned by Eugenia T. Primero.
- In the early 1980s, Eugenia leased the property to Irene Montecalvo for P500.00 per month.
- On January 13, 1985, an un-notarized Agreement was executed wherein Eugenia offered to sell the property to Irene for P1,000.00 per square meter, with a down payment of P40,000.00.
- The Agreement stipulated a negotiation period of 30 to 45 days to finalize the sale, with penalties for non-compliance by either party.
- Irene made partial payments totaling P293,000.00 but failed to complete the down payment within the agreed period.
- Eugenia did not return the deposit and refused further payments after 1992, leading to disputes regarding the property's ownership.
Legal Proceedings
- On May 13, 1996, Eugenia and her heirs filed a complaint for unlawful detainer against Irene and Nonilon Montecalvo, which was dismissed for lack of jurisdiction.
- Subsequently, Irene and Nonilon filed a case for specific performance in June 1996 to compel Eugenia to convey the 293-square meter portion of the property.
Trial Court Proceedings
- The Regional Trial Court (RTC) heard the ca