Dihiansan v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondent Jose Serrano was the registered owner of a parcel of land. The Archbishop of Caceres offered to sell portions of its land to widen Ateneo Avenue, and respondent Serrano, as an adjoining owner, had a preferential right to purchase. Petitioner Benjamin Dihiansan, an employee of respondent Serrano, requested to purchase the disputed property under certain conditions. On February 3, 1967, Dihiansan executed a contract (Exhibit "A") obligating himself to re-sell the property to Serrano at P2,500 and not to sub-lease it. On the same date, Dihiansan executed another document (Exhibit "B") obligating himself to pay Serrano a monthly "honorarium" of P20.00 until Serrano repurchased the lot. On May 2, 1970, after verbal demands failed, Serrano demanded in writing that Dihiansan re-sell the property, but Dihiansan refused. Serrano later discovered that Dihiansan had sold the property to Ramon King for P4,500.00. Procedural History: Serrano filed a complaint against Dihiansan. Upon learning of the sale to King, Serrano amended his complaint to implead King. Dihiansan contended that he acquired the property unconditionally prior to Exhibit "A", that Exhibit "A" was executed without his wife's consent, that Exhibit "B" was void for lack of consideration, that the land in Exhibit "A" differed from that in the complaint, and that he had already sold the land to King. King claimed to be the absolute owner, having purchased in good faith and for value. The trial court ruled in favor of Serrano, declaring the sale to King null and void, and ordering Dihiansan to pay defaulted honorarium payments and damages. The Court of Appeals affirmed the trial court's decision. The Petition: Petitioners (Dihiansan and his wife) sought review of the Court of Appeals' decision, arguing that Exhibit "A" was void for lack of consideration, that the sale to King was not made in bad faith, and that the identity of the property was different.
Issue(s)
Whether Exhibit "A" is null and void for lack of cause or consideration. Whether the sale of the disputed property to Ramon King was effected in bad faith. Whether the identity of the disputed property was sufficiently established. Whether the issue of Article 1622 of the Civil Code (right of preemption/redemption) can be raised for the first time on appeal.
Ruling
The Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals, upholding the trial court's judgment in favor of respondent Jose Serrano.
Ratio Decidendi
On the validity of Exhibit "A" for lack of cause or consideration: The Court held that the allegation is untenable. The consideration for Exhibit "A" was the private respondent's preferential right to buy the property. The contract clearly stipulated that petitioner Dihiansan would re-sell the property to the private respondent. The Court emphasized that a contract is the law between the parties, and when its terms are plain and readily understandable, there is no room for construction. The written agreement is presumed to contain all the terms of the agreement. On the allegation of no fraud or bad faith in the sale to King: The Court found this contention untenable, stating that fraud was established. The trial court noted that King did not present evidence and merely affirmed Serrano's contention that Dihiansan sold the land in bad faith. The Court highlighted that the sale was incomplete and full title had not yet passed to King, as the deed of sale was not registered, which is the culminating act to complete the alienation of registered land. The finding of fraud was a factual finding entitled to great weight on appeal. On the identity of the disputed property: The Court found that the identity of the disputed property was clearly established by the parties' pleadings. Petitioner Dihiansan's admission in his answer to paragraph 6 of the complaint showed he acknowledged the identity of the land. The Court stated that a mistake in designating the lot number in a document does not vitiate the consent or affect the validity of the contract, as parties buy property as they see it by its physical metes and bounds. The Court also noted Dihiansan's inconsistent positions regarding the property's identity. On raising Article 1622 of the Civil Code for the first time on appeal: The Court held that this issue is a question of fact that should have been raised in the lower court. Since petitioners waived their right to present testimonial evidence and chose to remain silent, they are barred from raising this issue for the first time on appeal. The Court reiterated the well-settled rule that, except for questions of jurisdiction, no question will be entertained on appeal unless it has been raised in the court below and is within the issues made by the parties in their pleadings.
Main Doctrine
Findings of fact of the Court of Appeals are conclusive on the parties and the Supreme Court, subject to certain recognized exceptions which have no application here. In reviews on certiorari, the Court addresses only questions of law, not the analysis or weighing of evidence.