Buiser v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Prudencio Maranan and Leovigilda Suarez (private respondents) filed a complaint against spouses Alfonso Buiser and Soledad Medrano-Buiser (petitioners) to recover P10,000.00. The petitioners, lessees of the "FILIPINO BAKERY," represented to the private respondents that they had a ten-year leasehold contract, with two years elapsed, and offered to sell their leasehold rights for P10,000.00, claiming their contract was misplaced. A deed of sale was executed on February 15, 1967, with possession to be transferred on March 30, 1967. However, on March 28 or 29, 1967, the private respondents learned that the petitioners' lease was only month-to-month with the owner, Apolonio Buquid. The owner, Buquid, arrived and intended to retake possession. The petitioners subsequently returned possession to Buquid. The private respondents demanded the return of their P10,000.00, which the petitioners refused. Procedural History: The trial court dismissed the complaint. On appeal, the Court of Appeals reversed the trial court's decision, ordering the petitioners to refund P14,000.00 with interest and attorney's fees. A motion for reconsideration was denied. The Petition: The petitioners seek review of the Court of Appeals' decision, arguing that the appellate court erred in making findings of fact based on speculation, in not upholding the trial court's findings, in not holding that a deed of surrender was executed solely to prevent the collection of rentals, and in not ordering the private respondents to pay the balance of P4,000.00.
Issue(s)
Whether the Court of Appeals erred in making its own findings of fact contrary to the trial court's findings. Whether the Deed of Surrender (Exhibit "C") was executed solely to prevent the petitioners from collecting monthly rentals from the private respondents. Whether the private respondents are liable to pay the petitioners the balance of P4,000.00.
Ruling
The petition is DISMISSED. The decision of the Court of Appeals is AFFIRMED. The award of P14,000.00 to the private respondents shall bear legal interest.
Ratio Decidendi
On the alleged error in findings of fact: The Supreme Court found no reversible error in the Court of Appeals' ruling. The Court emphasized that when the terms of an agreement have been reduced to writing, the writing is considered to contain all the terms, and no other evidence is admissible, except under specific exceptions outlined in Rule 130, Section 7 of the Rules of Court. The Court found that the Deed of Sale (Exhibit "A") and the Deed of Surrender (Exhibit "C") were clear and unambiguous. The petitioners' claim that Exhibit "C" did not reflect the true intent was not supported by evidence falling under the exceptions. Therefore, the Court of Appeals' interpretation of the written documents was upheld. On the nature and purpose of the Deed of Surrender (Exhibit "C"): The Supreme Court affirmed the Court of Appeals' finding that Exhibit "C" constituted a valid termination of the verbal contract of lease between the petitioners and the owner, Apolonio Buquid, and a surrender of the premises. The Court rejected the petitioners' contention that Exhibit "C" was merely to prevent them from collecting rent from the private respondents. The explicit language of Exhibit "C" stated the termination of the verbal lease and the surrender of the bakery by the lessee (Alfonso Buiser) to the lessor (Apolonio Buquid). This written agreement, according to the Rules of Court, is conclusive as to its terms. On the claim for the balance of P4,000.00: The Supreme Court found no reversible error in the Court of Appeals' finding that there was an advance payment of P4,000.00 as an initial payment for the purchase of leasehold rights, and that the total consideration was P10,000.00 as acknowledged in the Deed of Sale (Exhibit "A"). The petitioners' own pre-trial contention that the consideration for the aborted sale was P18,000.00 further contradicted their claim for a balance of P4,000.00 based on a P10,000.00 sale. Moreover, the subsequent surrender of the leasehold rights to the owner meant that the petitioners no longer possessed the rights they purported to sell, thus negating any claim for further payment based on that sale.
Main Doctrine
A written agreement, absent any exception under Rule 130, Section 7 of the Rules of Court, is considered as containing all the terms of the agreement, and no evidence of other terms can be admitted. Furthermore, the surrender of a leasehold interest, evidenced by a written agreement, terminates the lessee's rights and obligations, even if a prior sale of such rights had been executed.