TITLE VI, BOOK IV OF THE CIVIL CODE OF THE PHILIPPINES:
A CASE DIGEST ON G.R. NOS. 135634, MAY 31, 2000
In Partial Fulfillment of the Requirements
In ACC 312 – Regulatory Framework and Business Transactions (918)
First Semester A. Y. 2024-2025
Submitted by:
Hannah V. Yap
Submitted to:
Atty. Lord Anthony Pusod
Professor
October 16, 2024
[G.R. Nos. 135634, May 31, 2000]
HEIRS OF JUAN SAN ANDRES (VICTOR S. ZIGA) AND SALVACION S.
TRIA, PETITIONERS, VS. VICENTE RODRIGUEZ, RESPONDENT.
Facts
Juan San Andres was the registered owner of Lot No. 1914-B-2 in Liboton,
Naga City. The sale was evidenced by a deed of sale. On September 28, 1964, he
sold a 345 sqm portion to Vicente Rodriguez. Following San Andres’ death in 1965, a
dispute arose over an additional 509 sqm that Rodriguez claimed to have also
purchased from San Andres, leading to a legal battle involving the estate’s judicial
administrator, Ramon San Andres, and Rodriguez’s heirs, since both original parties
had passed away. Ramon San Andres hired geodetic engineer Jose Panero and
prepared a consolidated plan of the estate and also prepared a sketch plan of the lot
sold to the respondent. It was found out that the respondent had enlarged the area
which he purchased from Juan.
The administrator sent a letter to the respondent to vacate the said portion in
which the latter refused to do. The dispute led to a lawsuit filed by the estate’s
administrator in 1987 for recovery of possession of the 509 sqm. Through his legal
maneuvers, Rodriguez countered that he had a verbal agreement with San Andres
for the additional area, supporting his claim with a receipt and correspondence from
the estate’s administrator. He also alleged that under the consent of Juan, he took
possession of the same and introduced improvements thereon. The respondent
deposited in court the balance of the purchase price amounting to P7,035.00 for the
aforesaid 509 sqm lot.
After the trial court sided with the San Andres heirs, the Court of Appeals
reversed the decision, prompting the heirs to seek a review from the Supreme Court.
Issues
1. Whether the receipt acknowledged a contract to sell despite lacking
precise description of the object.
2. Whether the respondent (Rodriguez’s heirs) should be obliged to fulfill the
condition of payment for a sale to be considered binding.
3. The validity of consignation for the balance of the purchase price despite
alleged noncompliance with mandatory requirements.
4. The applicability of laches and prescriptions in contesting the agreement
after 24 years.
Ruling of the Trial Court
Decision:
On September 20, 1994, the trial court rendered judgment in favor of the
petitioner. It ruled that there was no contract of sale due to the lack of a valid object
because there was no sufficient indication to identify the property subject of the sale,
hence, the need to execute a new contract.
Ruling of the Court of Appeals
Decision:
The respondent appealed to the Court of Appeals. On April 21, 1998, the
appellate court rendered a decision reversing the decision of the trial court and held
that the object of the contract was determinable, and that there was a conditional
sale with the balance of the purchase price payable within five years from the
execution of the deed of sale.
The Civil Code states that a contract of sale obligates one party to transfer
ownership of a determinate thing, while the other agrees to pay a price in money or
its equivalent. A sale may be absolute or conditional. The essential elements of a
sale are:
a) Consent to transfer ownership for a price;
b) Determinate subject matter; and
c) A certain price in money or its equivalent.
In a receipt dated September 29, 1964, Juan San Andres acknowledged
receiving P500.00 as an advance payment for a residential lot adjoining a previously
paid lot on three sides. The agreed price was P15.00 per square meter, with the final
amount based on a survey and due in five years from the deed of sale.
The petitioner’s claim lacks merit. The respondent purchased a portion of Lot
1914-B-2, consisting of 345 square meters, part of an 854-square-meter area. This
"previously paid lot" was clearly defined, and the adjoining lot sold is determine,
despite the final area depending on a survey.
In addition, the object of the sale is certain and determinate. Under Article
1460 of the New Civil Code, a thing is considered determinate if, at the time the
contract is made, it can be identified without the need for a new or further agreement
between the parties. In this case, this definition is fully met.
The Court of Appeals considered the stipulation that full payment, based on a
survey, would be due within five years as a "condition" of the sale. However, the
vendor, Juan San Andres, sold the residential lot to the respondent without any
reservation or condition. There was no clause reserving ownership until full payment
or allowing the seller to cancel the contract if the buyer failed to pay.
Thus, the contract of sale is considered absolute, not conditional, since the lot
was delivered, and ownership transferred upon delivery. The stipulation regarding
the payment timeline only addresses how the full price is to be calculated and when
it is due, but it does not affect the validity of the sale. Therefore, the lack of a formal
deed does not prevent the sale from being effective.
Ruling of the Court
Decision:
The Supreme Court affirmed the appellate court’s ruling, holding that the sale
transaction was valid and binding, countering each issue raised by the petitioners:
1. The court found the property to be sufficiently determinate, determinable
through a survey linked to the original 345 sqm portion sold.
2. It held the agreement to be an absolute sale, not conditional, with the receipt
and subsequent correspondences serving as proof of a perfected contract.
3. The Court clarified that consignation wasn’t directly addressed in the appellate
court’s decision but deemed Rodriguez’s act of depositing the balance into
court as appropriate given the circumstances.
4. It ruled out laches and prescription, emphasizing that the sale was
consummated upon delivery, with Rodriguez and subsequently his heirs
seeking to complete their obligations.
