Case Summary (G.R. No. 140715)
Background of the Sale
On May 1, 1979, Josefina, through a Special Power of Attorney, authorized her son Carlos, Jr. to sell portions of the land to businessman Jose Lagon. In the subsequent deed of absolute sale executed on May 9, 1979, it was stipulated that a portion of the land was sold for P 80,000, although the actual sale price was P 163,760. This discrepancy regarding payment and additional conditions led to issues between the parties.
Conditions of the Sale
The sale included a specific condition that Lagon should transfer a rural bank onto the lot and construct a commercial building within five years of the sale. However, the deed itself did not incorporate these conditions, raising a conflict regarding contractual obligations. Lagon later failed to meet these conditions, leading to Josefina's refusal to deliver the title for the sold property.
Lagon's Actions and Legal Proceedings
Lagon filed a complaint against Josefina and Carlos, Jr. for specific performance, claiming they failed to provide him with the title and possession of the property. During trial, Lagon's testimony centered on his compliance efforts, including his claim that he had received permission from them to construct a bank on the property. Josefina and Carlos, Jr. countered that Lagon's failure to pay the full purchase price justified their refusal to transfer the title.
Trial Court's Decision
In January 1995, the Regional Trial Court ruled in favor of Lagon, forcing Josefina and Carlos, Jr. to execute the necessary documents to complete the sale and deliver the title. The trial court also awarded damages to Lagon.
Appeal and Court of Appeals' Rulings
Josefina and Carlos, Jr. appealed to the Court of Appeals, which initially reversed the trial court's decision but later amended that decision, affirming the trial court's ruling that a contract of sale had been executed between the parties. It evaluated the conditions laid out in the affidavit and the Special Power of Attorney and concluded that they were integral to the sale.
Supreme Court's Analysis
The Supreme Court reviewed whether the nature of the agreement was a contract to sell or a contract of sale. Ultimately, it determined that the deed of absolute sale constituted a contract of sale as it expressed the full intent of parties involved. Ho
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Case Background
- This case involves a petition for review on certiorari of the Amended Decision of the Court of Appeals which affirmed the decision of the Regional Trial Court in Civil Case No. 778.
- The property in question is a parcel of land measuring 24,725 square meters in Isulan, Sultan Kudarat, owned by Carlos Valdez, Sr. and Josefina de Leon Valdez.
- Upon Carlos Valdez, Sr.'s death, his widow, Josefina, and their children became the heirs to the property, which was covered by Transfer Certificate of Title No. T-19529.
Sale of Property
- In December 1978, Josefina subdivided the property into eight lots (3-A to 3-H) to enhance its value.
- On May 1, 1979, Josefina granted her son, Carlos, Jr., a Special Power of Attorney to sell portions of Lot No. 3 to Jose Lagon.
- A Deed of Absolute Sale was executed on May 9, 1979, selling a part of Lot No. 3 for P80,000, although the actual sale price was P163,760.
- The sale included conditions requiring Lagon to construct a commercial building and transfer the Rural Bank of Isulan to the property.
Issues with Sale Execution
- The conditions for the sale were not incorporated into the deed; instead, an affidavit prepared by Carlos, Jr. was appended, indicating Lagon's obligations.
- Lagon failed to fulfill the conditions of the sale, including the construction of the commercial building and the payment of the