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8/3/2019 Araneta vs. Phil Sugar
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Araneta vs. Phi. Sugar Estate Dev., Inc
20 SCRA 330/GR L-22558
Art. 1197
Scope
➢ Art. 1197
Facts
➢ Petitioner and Respondent entered into a contract of purchase and sale with mortgage whereas P
sold a big tract of land to R subject to following conditions: 1) that buyer will build on said landthe Sto. Domingo Church and Convent and 2) that seller will construct streets surrounding the
land which shall be named “Sto. Domingo Avenue”➢ R finished the construction of the church will P was unable to finish the construction of the
streets because a third party, occupying the middle part thereof, refuse to vacate the same➢ R filed a complaint seeking P to comply with the obligation and/or pay damages in case of
failure/refusal➢ RTC and CA decided in favor of R and gave P 2 years to comply with its obligation
Held
1. Art. 1197 involves two step processes: 1) the Court must first determine that the obligation
does not fix period (or that the period is made to depend upon the will of the debtor), but
from the nature and the circumstances it can be inferred that a period was intended (Art
1197 1&2) and 2) the Court must proceed to second step and decide what period was
probably contemplated by parties.
➢ Even on the assumption that the court should have found out that no reasonable time or period
at all had been fixed, the COMPLAINT NOT HAVING SOUGHT THE COURT SHOULD
SET A PERIOD, the court could not proceed to do so unless the complaint is amended➢ No basis to support the conclusion that period should be set at two years after finality of
judgment, considering that the land was occupied by squatters. Parties must comply with legal
processes in evicting the squatters. Reasonable time: at the date all the squatters on affected
areas are finally evicted