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Philippine Supreme Court Case Digests

Case Digests for Philippine Law Students

POSTED IN OBLIGATIONS AND CONTRACTS

Marin v. Adil G.R. No. 47986

Facts:

The Armadas were expecting to inherit some lots from their uncle. Marin had hereditary rights in the estates
of her parents. A deed of exchange was executed wherein it was stipulated that both parties acknowledge
that the exchange operates to their individual and mutual benefit and advantage, for the reason that the
property being ceded, transferred, conveyed and unclaimed by one party to the other is situated in the place
where either is a resident resulting in better administration of the properties. But the expected land was
adjudicated to Soledad, sister of Marin. So, the Armadas and other heirs sued Soledad for claiming to be the
sole heir of their uncle, but ended in a compromise where the Armadas were awarded two lots. Marin
waived, renounced and quitclaimed her share in her parents estate in favour of her another sister Aurora.
She cannot anymore fulfil her obligations in her signed deed of exchange with the Armadas. The Armadas
filed a rescisorry action against Marin.

Issue:

Did Armadas action prescribe?

Held:

No. The action to declare contracts void and inexistent does not prescribe. It is evident from the deed of
exchange that the intention of the parties relative to the lots cannot be definitely ascertained. This
circumstance renders the exchange void.

December 21, 2011

Rongavilla v. CA G.R. No. 83974

Facts:

The Dela Cruz sisters were the aunts of Dolores Rongavilla. They borrowed P2,000 from the Rongavillas to
have their rooftop repaired. Later, petitioners went back to their aunts to have them sign a contract. Taking
advantage of their lack of education, the sisters were made to believe that such document, typewritten in
English, was just for the acknowledgment of their debt. After four years, petitioners asked their aunts to
vacate the land subject to litigation claiming that she and her husband were the new owners. After verifying
with the Registry of Deeds, the aunts were surprised that what they have signed was actually a deed of
sale. Their land title was cancelled and the ownership was transferred to their nephews. The land was
mortgaged with the Cavite Development Bank.
Issue:

Was the deed of sale void?

Held:

Yes. While petitioners claimed they were regularly paying taxes on the land in question, they had no second
thoughts stating at the trial and on appeal that they had resorted to doctoring the price stated in the
disputed Deed of Sale, allegedly to save on taxes. While it is true that public documents are presumed
genuine and regular under the Rules of Court, this presumption is a rebuttable presumption which may be
overcome by clear, strong and convincing evidence.

December 21, 2011

Cristobal v. Gomez G.R. No. 27014

Facts:

Epifanio sold a property with pacto de retro to Yangco. It was stipulated that the property is redeemable
within five years. When the period expired, Yangco extended it. In order to redeem, Epifanio asked Banas for
a loan. Banas agreed, with the condition that Marcelino and Telesfora be responsible for the loan. The two
entered into a private partnership in participation which stipulated that the property shall be returned to
Epifanio as soon as the capital employed have been covered. Epifanio died. He left Paulina and their
children. Marcelino acquired exclusive rights over the property when Telesfora conveyed her interest to him.
Marcelino sold the property to Banas, with pacto de retro, redeemable within five years. He redeemed it from
Banas. Marcelino submitted a notarial document wherein Epifanio certifies that Marcelino had requested
him to draw up a notarial act showing the properties which Marcelino was known to be the true owner.
Marcelino relies upon this instrument as proving title in him, contending that Epifanio and his successors are
estopped from claiming said lot.

Issue:

Are the heirs of Epifanio estopped from claiming the property?

Held:

No. Estoppel may not be invoked by a person party to the collusion, by reason that he could not have been
misled. The document executed by Epifanio was merely laying the basis of a scheme to defeat Yangcos
rights under his contract of purchase of 1891, or to defeat Epifanios other creditors.

December 21, 2011

DBP v. CA G.R. No. 28774

Facts:

DBP bought 91,188.30 square meters of land, consisting of 159 lots, in the proposed Diliman Estate
Subdivision of the PHHC. However, the sale of the lots to DBP, Lots 2 and 4, which form part of said 159 lots,
were still sold by PHHC to the spouses Nicandro, for which 2 deeds of sale were issued to them by PHHC.
Upon learning of PHHCs previous transaction with DBP, the spouses filed a complaint against DBP and the
PHHC to rescind the sale of Lots 2 and 4 by PHHC in favor of DBP. The CFI held that the sale of Lots 2 and 4,
to DBP is null and void, for being in violation of Section 13 of the DBP Charter.

Issue:

Do the spouses possess the legal personality to question the legality of the sale?

Held:

Yes. The spouses stand to be prejudiced by reason of their payment in full of the purchase price for the
same lots which had been sold to DBP by virtue of the transaction in question.The general rule is that the
action for the annulment of contracts can only be maintained by those who are bound either principally or
subsidiarily by virtue thereof. However, a person who is not obliged principally or subsidiarily in a contract
may exercise an action for nullity of the contract if he is prejudiced in his rights with respect to one of the
contracting parties, and can show the detriment which could positively result to him from the contract in
which he had no intervention.

December 21, 2011

Goldenrod v CA G.R. No. 126812

Facts:

Barretto owned parcels of land which were mortgaged to UCPB. Barretto failed to pay; the properties were
foreclosed. Goldenrod made an offer to Barretto that it would buy the properties and pay off the remaining
balance of Barrettos loan with UCPB. It paid Barretto 1 million pesos as part of the purchase price. The
remaining balance would be paid once Barretto had consolidated the titles. On the date that Goldenrod was
supposed to pay, Goldenrod asked for an extension. UCPB agreed. When the extension date arrived,
Goldenrod asked for another extension. UCPB refused. Barretto successfully consolidated the
titles. Goldenrod informed Barretto that it would not be able to push through with their agreement. It asked
Barretto to return the 1 million pesos. Barretto did not give in to Goldenrods rescission. Instead, it sold the
property that was part of their agreement to Asiaworld.

Issue:

Should Goldenrod be paid back the 1 million pesos?

Held:

Yes. Rescission creates the obligation to return the things which were the object of the contract together
with the fruits and interest. Barretto is obliged to pay Goldenrod back because 1) Goldenrod decided to
rescind the sale; 2) the transaction was called off and; 3) the property was sold to a third person. By virtue of
the extrajudicial rescission of the contract to sell by Goldenrod, without opposition from Barretto, who in
turn sold it to a third person, Barretto had the obligation to return the 1 million pesos plus legal interest from
the date it received the notice of rescission.

December 21, 2011

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Recent Posts

Marin v. Adil G.R. No. 47986

Rongavilla v. CA G.R. No. 83974
Cristobal v. Gomez G.R. No. 27014
DBP v. CA G.R. No. 28774
Goldenrod v CA G.R. No. 126812

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