This document summarizes three Philippine Supreme Court cases related to contracts:
1) The first case involved a proposed land sale that was not perfected because the buyers did not pay the price or deposit. The court found no valid contract for specific performance.
2) The second case determined a land transaction was a deed of absolute sale, not a contract to sell, because the elements of a land sale contract were met.
3) The third case ruled a contract for supplying and installing air conditioning systems was for services, not goods, so the company was not subject to sales tax on manufactured goods.
This document summarizes three Philippine Supreme Court cases related to contracts:
1) The first case involved a proposed land sale that was not perfected because the buyers did not pay the price or deposit. The court found no valid contract for specific performance.
2) The second case determined a land transaction was a deed of absolute sale, not a contract to sell, because the elements of a land sale contract were met.
3) The third case ruled a contract for supplying and installing air conditioning systems was for services, not goods, so the company was not subject to sales tax on manufactured goods.
This document summarizes three Philippine Supreme Court cases related to contracts:
1) The first case involved a proposed land sale that was not perfected because the buyers did not pay the price or deposit. The court found no valid contract for specific performance.
2) The second case determined a land transaction was a deed of absolute sale, not a contract to sell, because the elements of a land sale contract were met.
3) The third case ruled a contract for supplying and installing air conditioning systems was for services, not goods, so the company was not subject to sales tax on manufactured goods.
This document summarizes three Philippine Supreme Court cases related to contracts:
1) The first case involved a proposed land sale that was not perfected because the buyers did not pay the price or deposit. The court found no valid contract for specific performance.
2) The second case determined a land transaction was a deed of absolute sale, not a contract to sell, because the elements of a land sale contract were met.
3) The third case ruled a contract for supplying and installing air conditioning systems was for services, not goods, so the company was not subject to sales tax on manufactured goods.
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Case Title People’s Homesite & Housing Corp. G.R. No. G.R. No.
L-61623 | December 26,
vs. CA | Date 1984 Facts The PHHC board of directors proposed a consolidation subdivision plan subject to the approval of the Quezon City Council and the same will be awarded to Spouses Mendoza subject to the approval of the OEC (PHHC) Valuation Committee and higher authorities. However, the city council disapproved the proposed consolidation subdivision plan. Another revised plan was prepared and submitted to the city council for approval which included Lot 4 was approved by the city council. The Mendozas never paid the price of the lot nor made the 20% initial deposit, thus, re-awarded to other awardees who made the initial deposit. The Spouses Mendoza asked for reconsideration of the withdrawal of the previous award to them and filed the instant action for specific performance and damages. The trial court sustained the withdrawal of the award. However, upon appeal of the Spouses Mendoza, the CA reversed the lower court’s decision and directed the PHHC to sell to the Mendozas Lot 4. The PHHC appealed to this Court. Issue Whether there was a perfected sale to the Mendozas which they can enforce against the PHHC by an action for specific performance. Rulings NO. The contract of sale is perfected at the moment there is a meeting of minds upon the thing which is the object of the contract and upon the price. From that moment, the parties may reciprocally demand performance, subject to the law governing the form of contracts. Under the facts of this case, we cannot say there was a meeting of minds on the purchase of Lot 4 with an area of 2,608.7 square meters at P21 a square meter.
Case Title G.R. No.
Dignos vs. CA G.R. No. L-59266 | February 29, 1988 | Date Facts On June 7, 1965, petitioners sold a parcel of land to herein plaintiff-appellant Jabil with stated installments. However, on November 25, 1965, the Dignos spouses sold the same land in favor of defendant Spouses Cabigas. As the Dignos spouses refused to accept from plaintiff-appellant the balance of the purchase price of the land, and as plaintiff- appellant discovered the second sale made by defendants-appellants to the Cabigas spouses, plaintiff-appellant brought the present suit. Petitioners, appealing in this Court the decisions of the trial court and the CA, raised that the CA erred in holding that the its contract with plaintiff-appellant is a deed of absolute sale. Issue Whether the subject contract is a deed of absolute sale or a contract Lot sell. Rulings This Court ruled that all the elements of a valid contract of sale under Article 1458 of the Civil Code, are present, such as: (1) consent or meeting of the minds; (2) determinate subject matter; and (3) price certain in money or its equivalent. In addition to, Article 1477 of the same Code provides that "The ownership of the thing sold shall be transferred to the vendee upon actual or constructive delivery thereof.” And in the absence of stipulation to the contrary, the ownership of the thing sold passes to the vendee upon actual or constructive delivery thereof. In the present case, the trial court found that the Dignos spouses delivered the possession of the land in question to Jabil. However, the CA found that the acts of petitioners, contemporaneous with the contract, clearly show that an absolute deed of sale was intended by the parties and not a contract to sell. Thus, the subject contract is a deed of absolute sale.
Case Title G.R. No.
Acap v. CA G.R. No. 118114 | December 7, 1995 | Date Facts After spouses Santiago Vasquez and Lorenza Oruma died, their only son Felixberto inherited the lot and the latter executed a duly notarized document entitled "Declaration of Heirship and Deed of Absolute Sale" in favor of Cosme Pido. Petitioner Acap had been the tenant of a portion of the said land. When ownership was transferred by Felixberto to Cosme Pido, Acap continued to be the registered tenant thereof and religiously paid his leasehold rentals to Pido and thereafter, upon Pido's death, to his widow Laurenciana. Thereafter, private respondent sought for petitioner to personally inform him that he had become the new owner of the land and that the lease rentals thereon should be paid to him. Petitioner refused to recognize private respondent's ownership over the subject land. He averred that he continues to recognize Cosme Pido as the owner of the said land, and having been a registered tenant therein since 1960, he never reneged on his rental obligations. Issue Whether the said document can be considered a deed of sale in favor of private respondent of the lot in question. Rulings NO. This Court ruled that in a Contract of Sale, one of the contracting parties obligates himself to transfer ownership of and to deliver a determinate thing, and the other party to pay a price certain in money or its equivalent. Private respondent, being then a stranger to the succession of Cosme Pido, cannot conclusively claim ownership over the subject lot on the sole basis of the waiver document which neither recites the elements of either a sale, or a donation, or any other derivative mode of acquiring ownership.
Case Title Andres Quiroga v. Parsons Hardware G.R. No.
G.R. No. 11491 | August 23, 1918 Co. | Date Facts A contract was entered into by and between the plaintiff and J. Parsons (to whose rights and obligations the present defendant later subrogated itself). Plaintiff alleged in the complaint the defendant violated the following obligations: not to sell the beds at higher prices than those of the invoices; to have an open establishment in Iloilo; itself to conduct the agency; to keep the beds on public exhibition, and to pay for the advertisement expenses for the same; and to order the beds by the dozen and in no other manner. He further alleged that the defendant was his agent for the sale of his beds in Iloilo, and that said obligations are implied in a contract of commercial agency. Issue Whether the defendant, by reason of the contract hereinbefore transcribed, was a purchaser or an agent of the plaintiff for the sale of his beds. Rulings NO. This Court ruled that the contract by and between the plaintiff and the defendant was one of purchase and sale. There was the obligation on the part of the plaintiff to supply the beds, and, on the part of the defendant, to pay their price. These features exclude the legal conception of an agency or order to sell whereby the mandatory or agent received the thing to sell it, and does not pay its price, but delivers to the principal the price he obtains from the sale of the thing to a third person, and if he does not succeed in selling it, he returns it.
Case Title Commissioner of Internal Revenue G.R. No.
v. Engineering Equipment and | Date G.R. No. L-27044 | June 30, 1975 Supply Co. Facts The Commissioner contends that Engineering is a manufacturer and seller of air conditioning units and parts or accessories thereof and, therefore, it is subject to the 30% advance sales tax prescribed by Section 185(m) of the Tax Code. Engineering claims that it is not a manufacturer and setter of air-conditioning units and spare parts or accessories thereof subject to tax under Section 185(m) of the Tax Code, but a contractor engaged in the design, supply and installation of the central type of air-conditioning system subject to the 3% tax imposed by Section 191 of the same Code, which is essentially a tax on the sale of services or labor of a contractor rather than on the sale of articles subject to the tax referred to in Sections 184, 185 and 186 of the Code. Issue Whether Engineering made a manufacture and sell of air-conditioning units and liable to the advance sales tax under Section 185(m). Rulings NO. This Court ruled that pursuant to Art. 1467. A contract for the delivery at a certain price of an article which the vendor in the ordinary course of his business manufactures or procures for the general market, whether the same is on hand at the time or not, is a contract of sale, but if the goods are to be manufactured specially for the customer and upon his special order and not for the general market, it is a contract for a piece of work. In this case, Engineering did not manufacture air conditioning units for sale to the general public, but imported some which were used in executing contracts entered into by it. Thus, it definitely did not and was not engaged in the manufacture of air conditioning units but had its services contracted for the installation of a central system.