Case Summary (G.R. No. 204039)
Facts of the Case
In 1997, the respondents entered into a Contract to Sell with PPGI for a condominium unit in Kiener Hills. The total contract price was P1,151,718.75, with a down payment of P100,000.00 and a balance payable in 40 monthly installments. On April 23, 1998, PPGI entered into a Memorandum of Agreement (MOA) with UCPB, transferring the right to collect the contractual receivables from buyers, including the respondents, as part of a loan settlement arrangement.
Respondents' Complaint
On April 17, 2006, the respondents filed a complaint against PPGI and UCPB with the Housing and Land Use Regulatory Board (HLURB), claiming that despite having fully paid the purchase price, PPGI did not complete the condominium unit's construction.
HLURB Regional Office Decision
In its November 29, 2006, decision, the HLURB Regional Office ruled in favor of the respondents, ordering a refund from PPGI for failing to complete construction. However, it stated that UCPB was not solidarily liable as only the accounts receivable were assigned to it, and it suspended proceedings regarding PPGI, which was undergoing corporate rehabilitation.
HLURB Board Decision
On September 17, 2007, the HLURB Board reversed the Regional Office's decision, asserting UCPB was solidarily liable with PPGI as it had stepped into PPGI's role concerning Kiener Hills. It ruled that UCPB, as PPGI's successor-in-interest, was obligated to refund payments without prejudice to its rights against PPGI.
Office of the President Decision
The Office of the President affirmed the HLURB Board's decision on March 24, 2010, highlighting that the transfer of all rights and interests under the agreement established UCPB’s obligations, including the reimbursement of payments to the respondents.
Court of Appeals Ruling
The Court of Appeals (CA) modified the Office of the President's ruling on May 23, 2012. It clarified that UCPB was not solidarily liable with PPGI and restricted its liability to the amounts paid by the respondents during UCPB’s entitlement to the receivables. The CA referenced the precedent in United Coconut Planters Bank v. O'Halloran, highlighting that the assignment did not equate UCPB to the developer of Kiener Hills.
UCPB's Motion for Reconsideration
UCPB sought reconsideration of the CA's ruling, which was denied by a resolution on October 18, 2012, prompting UCPB to appeal the case.
Legal Issues Raised by UCPB
UCPB raised two primary issues on appeal: the misapplication of the O'Halloran case by the CA and its liability for amounts not actually received by UCPB.
Supreme Court Ruling on the Legal Issues
The Supreme Court found merit in UCPB’s petition, asserting that the appellate court had the authority to consider the actual amount of liability upon appeal. The Court emphasized that civil liabilities were intertwined with the determination of the liability amount, and reiterated that the doctrine of stare decisis applies only to decisions made by the Supreme Court, rendering the CA’s reliance on its own prior cases non-binding.
UCPB's Joint Liability
The Court acknowledged that UCPB was only jointly liable for reimbursing respondents, as solidary liability would imply an assumption of development obligations, which the agreements did not support. The intent beh
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Case Overview
- This case involves a petition for review on certiorari filed by United Coconut Planters Bank (UCPB) against spouses Walter and Lily Uy concerning a contractual dispute over a condominium project, Kiener Hills.
- The petition seeks to reverse the decisions rendered by the Court of Appeals (CA) and the Office of the President (OP) regarding UCPB's liability in relation to the construction and payment disputes of the condominium units.
Factual Background
- In 1997, spouses Walter and Lily Uy entered into a Contract to Sell with Prime Town Property Group, Inc. (PPGI) for a unit in Kiener Hills, with a total price of P1,151,718.75.
- The payment structure included a down payment of P100,000 and 40 monthly installments of P26,297.97 from January 1997 to April 2000.
- On April 23, 1998, PPGI transferred its rights to collect receivables, including those from the Uys, to UCPB through a Memorandum of Agreement (MOA) as part of a settlement of PPGI’s loan with UCPB.
- The Uys filed a complaint against PPGI and UCPB in April 2006, claiming that despite full payment, PPGI failed to complete their units.
HLURB Regional Office Decision
- The HLURB Regional Office found the Uys entitled to a refund due to PPGI's failure to co