Ramento v. Cosuangco
REITERATIONFacts
The Antecedents: Plaintiffs-appellants, Fortunata Ramento and her children, sought to rescind the sale of eight parcels of land made by the spouses (Adriano Mendoza and Fortunata Ramento) to defendant-appellee, Guadalupe Cosuangco, in May 1944. The cause of action was the alleged non-payment of a portion of the purchase price amounting to P75,862.00. Procedural History: The case was filed in the Court of First Instance of Nueva Ecija. The trial court, presided over by Judge Francisco Arca, ruled in favor of the defendant, finding that the full purchase price had been paid. The plaintiffs perfected their appeal to the Supreme Court. The Appeal: The plaintiffs-appellants assigned several errors of fact and one error of law, primarily contesting the trial court's finding that the remaining balance of the purchase price had been paid. They argued that despite demands, the defendant failed to pay the P18,000 balance and that Fortunata Ramento was deceived into signing certain documents.
Issue(s)
Whether the trial court erred in finding that the full purchase price of the subject properties was paid by the defendant-appellee. Whether the plaintiffs-appellants are entitled to the rescission of the sale.
Ruling
The Supreme Court affirmed the decision of the trial court, holding that the full purchase price of the properties had been paid. Consequently, the plaintiffs-appellants' action for rescission was denied.
Ratio Decidendi
On Issue 1: The Supreme Court found no prejudicial error in the trial court's appraisal of the conflicting evidence regarding the payment of the purchase price. The Court gave significant weight to documentary evidence, specifically Exhibits 2 and 5. Exhibit 2, dated September 14, 1944, stated that the total price of the lots had been fully satisfied, and Exhibit 5, dated July 1, 1945, was a promissory note for a P150 loan from the defendant to Fortunata Ramento, attested by Fortunata's son. The Court found Fortunata's claim of deception in signing these documents incredible, especially since she did not take action for four years and later sought a loan from the alleged deceiver. The Court also noted that if the P150 was on account of the purchase price, Fortunata should have credited it in her complaint, which she did not. Furthermore, the fact that the defendant possessed transfer certificates of title in her name indicated that the purchase price, including the balance, must have been paid, as the deed of sale stipulated delivery of titles upon payment of the remaining price. On Issue 2: Since the Court affirmed the finding that the full purchase price was paid, the basis for the rescission of the sale was absent. The plaintiffs-appellants failed to establish non-payment as a ground for rescission. Therefore, the action for rescission was correctly dismissed by the trial court.
Main Doctrine
In cases involving rescission of sale due to alleged non-payment, the Supreme Court will give great weight to documentary evidence, such as receipts and acknowledgments of payment, especially when corroborated by credible testimony. Claims of deception in signing documents are viewed with skepticism if the party claiming deception subsequently enters into further transactions with the alleged deceiver without protest or legal action for a significant period. Furthermore, issues not properly raised and presented in the lower court are generally not considered on appeal.