Philippine Supreme Court Case Digests _ Case Digests for Philippine Law Students

7/7/2014 Philippine Supreme Court Case Digests | Case Digests for Philippine Law Students

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Philippine Supreme Court Case Digests

Case Digests for Philippine Law Students

DEC 21 2011OBLIGATIONS 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 partiesacknowledge 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. Butthe 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 infavour 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. Thiscircumstance renders the exchange void.

DEC 21 2011

OBLIGATIONS AND CONTRACTS

Rongavilla v. CA G.R. No. 83974



Facts:

The Dela Cruz sisters were the aunts of Dolores Rongavilla. They borrowed P2,000 from theRongavillas to have their rooftop repaired. Later, petitioners went back to their aunts to have them signa 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 husbandwere 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 wastransferred 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 nosecond 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 arepresumed genuine and regular under the Rules of Court, this presumption is a rebuttable presumptionwhich may be overcome by clear, strong and convincing evidence.


Cristobal v. Gomez G.R. No. 27014

Facts:

Epifanio sold a property with pacto de retro to Yangco. It was stipulated that the property isredeemable 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 beresponsible for the loan. The two entered into a private partnership in participation which stipulatedthat 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 propertywhen Telesfora conveyed her interest to him. Marcelino sold the property to Banas, with pacto deretro, redeemable within five years. He redeemed it from Banas. Marcelino submitted a notarialdocument 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 thisinstrument as proving title in him, contending that Epifanio and his successors are estopped fromclaiming 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 havebeen 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.


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 EstateSubdivision of the PHHC. However, the sale of the lots to DBP, Lots 2 and 4, which form part of said159 lots, were still sold by PHHC to the spouses Nicandro, for which 2 deeds of sale were issued to themby PHHC. Upon learning of PHHCs previous transaction with DBP, the spouses filed a complaintagainst 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 DBPCharter.

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 thesame lots which had been sold to DBP by virtue of the transaction in question.The general rule is thatthe 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 orsubsidiarily 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.


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 theremaining 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 thedate 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 withtheir 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 torescind 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 fromBarretto, 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.


Cabaliw v. Sadorra G.R. No. 25650

Facts:

Cabaliw was the second wife of Benigno. During their marriage, they bought 2 parcels of land. Theyhad a daughter Soledad. Benigno abandoned his wife Cabaliw, thus the latter filed an action in court

for support. The Court ordered Benigno to pay her P75 a month. However, Benigno did not pay andinstead sold their property to his son-in-law Soterro. The transaction was done without Isidoras

consent. Prior to the sale, Soterro already knew that there was a judgment rendered against his father-in-law but proceeded to buy the property anyway. When Cabaliw found out, she instituted an action

along with her daughter to recover the properties.

Issue:



Is there a presumption of fraud?

Held:

Yes. Alienations by onerous title are presumed fraudulent when made by persons against whome somejudgment has been rendered or some writ of attachment has been issued. Benigno was ordered by the

Court to pay Cabaliw support and he failed to do so. Instead, he sold his properties to his son-in-law. The close relationship between Benigno and Soterro is a badge of fraud. Soterro knew about the

judgment against Benigno but proceeded to purchase the properties anyway. He cannot be said to be apurchaser in good faith. The presumption of fraud is not overcome by the fact that the transactions

were all made in the nature of public instruments between Soterro and Benigno. The properties sold

were conjugal properties. These cannot be sold without Cabaliws consent.


Municipality of Cavite v. Rojas G.R. No. 9069

Facts:

The municipal council of Cavite by Resolution No. 10, leased to Rojas some 70 or 80 square meters of

Plaza Soledad, on condition that she pay rent quarterly in advance according to the schedule fixed inOrdinance No. 43, series of 1903 and that she obligate herself to vacate said land within 60 days

subsequent to notification to that effect. Upon such notification, however, she refused to vacate the

land, forcing the municipality to file a complaint before the CFI to order her to vacate the land. After ahearing of the case, the CFI dismissed the complaint.

Issues:

(1) Is the contract valid?

(2) If in the negative, what are the obligations of the parties?

Held: (1) No. Article 1271 of the Old Civil Code, prescribes that everything which is not outside the

commerce of man may be the object of a contract, and plazas and streets are outside of thiscommerce. Communal things that cannot be sold because they are by their very nature outside of

commerce are those for public use, such as the plazas, streets, common lands, rivers, fountains, etc.

(2) Rojas must restore and deliver possession of the land described in the complaint to the municipality

of Cavite, which in its turn must restore to her all the sums it may have received from her in the natureof rentals just as soon as she restores the land improperly leased.

DEC 20 2011

OBLIGATIONS AND CONTRACTS, TRANSPORTATION LAW



Eastern Shipping Lines, Inc. v. Margarine-Verkaufs-Union GmbH G.R. No. L-31087 93 SCRA 257

Facts:

MARGARINE-VERKAUFS-UNION, a corporation not engaged in business in the Philippines, was the

consignee of copra in bulk shipped from Cebu on board EASTERN SHIPPING LINESs vessel fordischarge at Hamburg, Germany. Petitioners bill of lading for the cargo provided that the contract

shall be governed by the laws of the Flag of the Ship carrying the goods. In case of average, same shallbe adjusted according to York-Antwerp Rules. While the vessel was off Gibraltar, a fire broke out

aboard the and caused water damage to the copra. EASTERN SHIPPING LINES rejectedMARGARINE-VERKAUFS-UNION GmbH s claim for payment.

Issue:

Should Article 848 of the Code of Commerce govern this case despite the bill of lading which expressly

contained for the application of the York-Antwerp Rules which provide for MARGARINE-VERKAUFS-

UNION GmbHs fun recovery of the damage loss?

Held:

No. We hold that the lower court correctly ruled the cited codal article to be not applicable in thisparticular case for the reason that the bill of lading contains an agreement to the contrary. There is a

clear and irreconcilable inconsistency between the York-Antwerp Rules expressly adopted by theparties as their contract under the bill of lading which sustains Easterns claim and the codal articlecited by Margarine which would bar the same.

A contract of adhesion as embodied in the printed bill of lading issued for the shipment to which theconsignee merely adhered, having no choice in the matter, and consequently, any ambiguity must be

construed against the author.

DEC 20 2011CORPORATION LAW

PNB v. Ritratto G.R. No. 142616 362 SCRA 216

Facts:

PNB-IFL, a subsidiary company of PNB extended credit to Ritratto and secured by the real estate



PNB-IFL, a subsidiary company of PNB extended credit to Ritratto and secured by the real estatemortgages on four parcels of land. Since there was default, PNB-IFL thru PNB, foreclosed the propertyand were subject to public auction. Ritratto Group filed a complaint for injunction. PNB filed a motion

to dismiss on the grounds of failure to state a cause of action and the absence of any privity betweenrespondents and petitioner.

Issue:

Is PNB privy to the loan contracts entered into by respondent & PNB-IFL being that PNB-IFL isowned by PNB?

Held:

No. The contract questioned is one entered into between Ritratto and PNB-IFL. PNB was admittedly

an agent of the latter who acted as an agent with limited authority and specific duties under a specialpower of attorney incorporated in the real estate mortgage.

The mere fact that a corporation owns all of the stocks of another corporation, taken alone is not

sufficient to justify their being treated as one entity. If used to perform legitimate functions, asubsidiarys separate existence may be respected, and the liability of the parent corporation as well asthe subsidiary will be confined to those arising in their respective business. The courts may, in the

exercise of judicial discretion, step in to prevent the abuses of separate entity privilege and pierce theveil of corporate entity.

DEC 08 2011

LEAVE A COMMENTLOCAL GOVERNMENT

Alvarez v. Guingona G.R. No. 118303 252SCRA 695

Facts:

On April 18, 1993, HB No. 8817, entitled An Act Converting the Municipality of Santiago into anIndependent Component City to be known as the City of Santiago, was filed in the House of

Representatives. Meanwhile, a counterpart of HB No. 8817, Senate Bill No. 1243, was filed in theSenate. On March 22, 1994, the House of Representatives, upon being apprised of the action of theSenate, approved the amendments proposed by the Senate.

Issue:

Does the passing of SB No. 1243, the Senates own version of HB No. 8817, into Republic Act No. 7720be said to have originated in the House of Representatives as required?



Held:

Yes. Although a bill of local application should originate exclusively in the House of Representatives,the claim of petitioners that Republic Act No. 7720 did not originate exclusively in the House ofRepresentatives because a bill of the same import, SB No. 1243, was passed in the Senate, is untenablebecause it cannot be denied that HB No. 8817 was filed in the House of Representatives first before SB

No. 1243 was filed in the Senate.

The filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House, doesnot contravene the constitutional requirement that a bill of local application should originate in the

House of Representatives, for as long as the Senate does not act thereupon until it receives the Housebill.

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Philippine Supreme Court Case Digests _ Case Digests for Philippine Law Students