G.R. No.
102432 January 21, 1993
INTESTATE ESTATE OF THE LATE RICARDO P. PRESBITERO, SR., represented by its
Administrator, RICARDO PRESBITERO, JR., petitioner,
vs.
HONORABLE COURT OF APPEALS, and LEONARDO CAÑOSO, respondents.
Facts of the Case:
Ricardo Presbitero, Sr. entered into two (2) written contracts with private respondent
Leonardo Cañoso. The first contract entitled “Conformity of Agreement”, retained the services
of Mr. Cañoso to negotiate with the Land Bank of the Philippines (LBP) and the Ministry of
Agrarian Reform (MAR), under voluntary offer arrangement, of Hacienda Maria which
comprises some 270 hectares of land located in North Cotabato. The private respondent bound
himself to finish the processing and submission of documents within 120 days to Manila, by the
LBP and MAR. In the second contract, entitled as “Contract of Service,” Presbiterio bound
himself to compensate the private respondent for his efforts, services and other related
expenses in making the necessary follow up of the preparation, production of pertinent
documents required and to effect the recovery of the proceed of the land transfer payment
from LBP. In an amount equivalent to 25% of the gross total sales which is subject of Operation
Land Transfer. A third agreement was entered before Presbitero’s claim with LBP was
approved. The original fee with the private respondent is 25% but was reduced to 17 ½%.
However, when a part of the proceeds was released, Cañoso was not given his share as agreed
upon. Hence, the respondent filed a complaint against Presbitero before the RTC. Several
postponements were obtained by the petitioner. But, the motion was denied for the reason of
“financial handicap.” As a result, the court allowed the respondent to present his evidence as ex
parte. The RTC ordered Presbitero to pay the respondent 25% of the collectible.
Dissatisfied with the judgment, Presbitero appealed to the Court of Appeals. In its
decision, CA modified the decision from reducing the principal award to private respondent
from 25% to 17 ½% of the amount to collected by Presbitero from the LBP.
Issue:
Whether or not the private respondent complied with the terms and conditions granting
the contract’s validity?
Ruling:
Obligations arising from contracts have the force of law between the contracting parties
should be complied with in good faith. Unless the stipulations in a contact are contrary to law,
morals, good customs, public order or public policy. In this case, the contracts entered inti by
the parties were valid contracts. It gave rise to reciprocal obligations which are defined as those
that arise from the same clause, and in which each party is a debtor and a creditor of the other.
In the interpretation of contracts, it is general rule that if the terms thereof are clear as
to the intention of the contracting parties, the literal meaning of the stipulations shall control.
In this case, it was clearly agreed upon by the contracting parties that the private respondent
would undertake the processing, negotiation, follow-up of Presbitero’s claim with the LBP
within 120 days.
And even if we are to assume that the private respondent breached the agreement by
not fully accomplishing his obligation within stipulated period, said breach was not of a nature
which would justify a rescission of the contract. Under Article 1234 of the New Civil Code, if the
obligation has been substantially performed in good faith, the obligor (private respondent) may
recover as though there had been a strict and complete fulfillment, less damages suffered by
the oblige (Presbitero). Presbitero’s correlative obligation must perforce be also fulfilled. There
is no evidence to indicate that the private respondent was remise or negligent in the
performance of his obligation.