Title
Supreme Court
Sta. Lucia Realty and Development, Inc. vs. Spouses Buenaventura
Case
G.R. No. 177113
Decision Date
Oct 2, 2009
Respondents purchased a lot, later found encroached by third parties due to petitioner’s negligence in issuing permits, leading to legal claims for possession, damages, and reimbursement.

Case Summary (G.R. No. 177113)

Factual Background

On January 16, 1996, the Buenaventura spouses filed a complaint before the Housing and Land Use Regulatory Board (HLURB) against Sta. Lucia Realty for specific performance, damages, and attorney's fees, asserting that they purchased a lot from a third party, Loida Gonzales Alfonso, which was erroneously subdivided and occupied by other individuals. Sta. Lucia Realty contended it had no dealings with the Buenaventura spouses regarding the contested lot, claiming it belonged to a joint-venture partner and asserting that the Buenaventuras built on an incorrect lot.

Proceedings and Initial Ruling

The HLURB Arbiter concluded that Sta. Lucia Realty was responsible for the situation due to its negligence in issuing construction permits for the incorrect lot. The Arbiter ordered Sta. Lucia Realty to vacate the conflicting lot or to reimburse the Buenaventuras at a specified market value, along with damages and attorney's fees.

Appeals and Subsequent Decisions

The HLURB’s decision was upheld by its Board of Commissioners and later by the Office of the President. The Court of Appeals affirmed these decisions, emphasizing Sta. Lucia Realty’s negligence and failure to fulfill obligations towards the Buenaventuras, resulting in a misidentification of the property.

Issues Presented

The Supreme Court was asked to determine if the Court of Appeals erred in affirming Sta. Lucia Realty’s liability for specific performance and the associated damages. The petitioner argued it had no contractual relationship with the respondents and suggested the necessity of involving other parties in the litigation.

Legal Principles Applied

In determining the rights of the Buenaventuras, the Court reaffirmed principles from the New Civil Code, particularly Article 1311, which emphasizes the assignability of contracts. The Court found no basis for claiming that Alfonso’s rights were non-transmissible, allo

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