Case Summary (G.R. No. L-21230)
Applicable Law
The decision referenced principles from the 1987 Philippine Constitution, as the date of the decision is in 1991. Additionally, key provisions of the Civil Code, specifically Articles 1357 and 1544, are applicable in analyzing contractual obligations and property rights in this case.
Facts of the Case
The litigations began when the petitioners, as heirs of Pantaleon Jomoc, filed a suit to recover ownership of a lot that was fictitiously sold to third parties. A Deed of Extrajudicial Settlement and Sale was executed between Maria Jomoc and Maura So in February 1979, where So made partial payments totaling P49,000.00 for the lot, yet the document was not fully signed or notarized. Subsequently, the heirs executed another settlement with spouses Lim on the same day, February 28, 1983, igniting the legal conflict regarding the legitimacy of each transaction.
Trial Court Findings
The trial court found that there was no evidence to prove that Maura So had abandoned her intent to complete the sale of the property. The court classified the case as one of double sale, ruling that the Lim spouses registered their deed of sale in bad faith due to the existing notice of lis pendens related to Civil Case No. 8983, which involved the same property.
Legal Issue: Enforceability of Contract
The petitioners argued that the contract with Maura So was unenforceable per the Statute of Frauds, contending that it lacked the necessary signatures and notarization. However, the appellate court recognized that the existence of partial payment and corresponding acceptance established a valid contract for the sale, irrespective of formality deficiencies. The critical requirement of mutual consent was fulfilled, thus affirming the contract's enforceability.
Findings on Double Sale and Good Faith
In determining the rights between Maura So and the spouses Lim, the courts referred to Article 1544 of the Civil Code, which governs ownership rights in cases of double sale. The ruling clarified that ownership belongs to the party who first recorded the sale in good faith. The courts opined that the Lim spouses, having been made aware of the previous transaction with Maura So and failing to seek suff
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Case Overview
- The case involves two consolidated petitions concerning the ownership of a lot in Cagayan de Oro City that belonged to the heirs of Pantaleon Jomoc.
- The primary question is whether private respondent Maura So abandoned her agreement to purchase the property, which would render a subsequent sale to petitioners Lim Leong Kang and Lim Pue King null and void.
Factual Background
- The lot in question is part of the estate of Pantaleon Jomoc and was allegedly sold fictitiously to third parties.
- Maria P. Vda. de Jomoc, acting as administratrix of the estate, filed a suit to recover the property in Civil Case No. 4750.
- During this legal action, Maura So entered into a preliminary agreement with the heirs, involving a Deed of Extrajudicial Settlement and Sale of Land for P300,000.00, although not all parties signed or notarized it.
- Maura So made partial payments totaling P49,000.00 towards the purchase.
- Meanwhile, Mariano So, Maura’s husband, who was involved in the prior litigation regarding the property, agreed to a Deed of Reconveyance favoring the Jomoc heirs in 1983, dismissing his appeal in the recovery case.
Subsequent Developments
- On February 28, 1983, the Jomoc heirs executed another