Irureta Goyena v. Tambunting
REITERATIONFacts
The Antecedents: The plaintiff owned a tract of land with a building at No. 20 Calle San Jose, Ermita, Manila, measuring 152.46 square meters. A broker, acting for the plaintiff, informed the defendant that the lot was for sale and, based on information from the plaintiff, stated its dimensions as 23 meters in front and 8 meters in depth. Procedural History: The plaintiff (appellee) filed an action against the defendant (appellant) to enforce a contract of sale. The lower court ruled in favor of the plaintiff. The Appeal: The defendant appealed the decision, arguing that he should not be obligated to pay the agreed price of P3,200 because the lot's actual area was less than represented, and he believed he was purchasing the property 'at so much a meter.' He sought a proportional reduction in price or rescission of the contract.
Issue(s)
Whether the contract of sale was perfected between the parties. Whether the defendant is entitled to a proportional reduction in price or rescission of the contract due to a discrepancy in the lot's area, given that the sale was for a fixed price and not by measure.
Ruling
The Supreme Court affirmed the judgment of the lower court, holding that the contract of sale was perfected and binding upon the parties. The defendant was ordered to pay the agreed price of P3,200.
Ratio Decidendi
On Issue 1: The Court found that a perfected contract of sale existed between the plaintiff and the defendant. This was evidenced by private documents signed by both parties on March 12, 1901, which specified a determinate thing (lot No. 20 Calle San Jose, Ermita) and a certain price (P3,200). According to Article 1450 of the Civil Code, a sale is perfected when the parties agree upon the object and the price, even if neither has been delivered. The Court emphasized that the private document was not merely a draft but a binding agreement, and under Article 1278, contracts are obligatory in whatever form they are entered into, provided the essential elements are present. The essential elements of a determinate thing, a certain price, and a meeting of the minds were all satisfied. On Issue 2: The Court ruled that the defendant was not entitled to a proportional reduction in price or rescission of the contract. The defendant's argument that he purchased the lot 'at so much a meter' was not supported by the written contract or any other evidence. Article 1471 of the Civil Code clearly states that in the sale of real estate for a fixed price, any increase or decrease in the area does not affect the contract, even if it differs from the area stated. This provision applies unless the sale was explicitly made at the rate of a certain price for a unit of measure or number, which was not the case here. The Court noted that the defendant's claim was based on a misunderstanding or assumption, and his willingness to sign if a reduction was made was not an admission of a contract by measure but an attempt to settle the dispute amicably. The Court also considered the plaintiff's statement about a potential reduction as a willingness to abate a trifle to avoid litigation, not as an acknowledgment of a contractual obligation to reduce the price.
Main Doctrine
The Court held that a contract of sale is perfected upon agreement on the determinate thing and the certain price, even without delivery, as per Articles 1450 and 1445 of the Civil Code. Furthermore, applying Article 1471, if a sale of real estate is made for a fixed price, any increase or decrease in the area does not affect the contract, even if it differs from the stated area, unless the sale was explicitly made at a rate per unit of measure. The defendant's claim that he bought 'by the meter' was not substantiated by the contract or evidence, thus he was bound by the fixed price of P3,200 for the specific lot.