Mapa v. Arroyo
REITERATIONFacts
The Antecedents: Jose Antonio Mapa (petitioner) entered into four contracts to sell with Labrador Development Corporation (Labrador) for lots in Barangay Hills Subdivision. Mapa agreed to make monthly installments over ten years. Mapa defaulted in payments starting December 1976. Labrador sent demand letters in May 1977 and June 1982 for unpaid installments, which Mapa ignored. Labrador sent a notarial cancellation of the contracts in August 1982. Subsequently, Labrador issued a certification holding the cancellation pending the complete development of a road lot cul-de-sac. Labrador later informed Mapa of the completion of road, sidewalk, curbs, and gutters and requested settlement of his account. Mapa tendered a check in December 1982, which Labrador refused, demanding full payment of P260,138.61 based on an agreement to pay in full after cul-de-sac development. Mapa claimed Labrador failed to provide water and light facilities and filed a complaint seeking direction for Labrador to provide these facilities and to issue a cease and desist order against cancellation. Procedural History: The Office of Adjudication and Legal Affairs (OAALA) of the Human Settlements Regulatory Commission (HSRC) dismissed Mapa's complaint, finding that Labrador had the right to rescind the contract after five years from Mapa's default, pursuant to Clause 7 of the contract. The Commission Proper, HSRC, affirmed the OAALA decision. The Office of the President, through the Deputy Executive Secretary, dismissed Mapa's appeal. Mapa then filed a special civil action for certiorari before the Supreme Court, alleging grave abuse of discretion by the executive branch. The Petition: Petitioner sought reversal of the Office of the President's decision, arguing that Presidential Decree No. 957 (PD 957) was applicable to the contracts to sell and that Labrador's failure to comply with its obligations under the decree precluded Labrador from rescinding the contracts.
Issue(s)
Whether Presidential Decree No. 957, enacted after the execution of the contracts to sell, is applicable to the said contracts. Whether the doctrine of last antecedent was correctly applied by the petitioner in interpreting Sections 20 and 21 of Presidential Decree No. 957. Whether Labrador Development Corporation substantially complied with its obligations under the contracts and PD 957, thereby justifying the rescission of the contracts.
Ruling
The petition is DISMISSED. The decision of the Office of the President is affirmed.
Ratio Decidendi
On the applicability of Presidential Decree No. 957: The Court held that Presidential Decree No. 957, which became effective on July 12, 1976, could not be given retrospective application to the contracts to sell executed on September 18, 1975, and in 1976. The obligations statutorily imposed by the decree could not have been intended by the parties to be part of their contracts executed before the law existed or was contemplated. The Court emphasized that PD 957 requires the owner or developer to construct facilities offered and indicated in approved plans, brochures, or advertisements, and no further written commitment was made by the developer beyond what was stipulated in Clause 20 of the contract. To impose obligations from PD 957 retroactively would be to add new obligations to the parties that were not part of their original agreement. On the application of the doctrine of last antecedent: The Court rejected petitioner's strained application of the doctrine of last antecedent to Sections 20 and 21 of PD 957. Petitioner argued that the phrase "which are offered and indicated in the approved subdivision or condominium plans, brochures, prospectus, printed matters letters or in any form of advertisements" only referred to "other forms of development" and not to "facilities, improvements, and infrastructures." The Court found this interpretation illogical and erroneous, stating that the conjunction "and" joins the enumerated items, and the qualifying phrase applies to all of them. The rule ad proximum antecedens fiat relatio nisi impediatur sentencia dictates that relative words refer to the nearest antecedent unless prevented by context, and here, the context supports the phrase applying to all preceding terms. On substantial compliance and justification for rescission: The Court found that the petitioner's insistence on the non-construction of the cul-de-sac as a ground for suspending installments was unavailing and appeared to be a justification for his default. The on-site inspection report indicated substantial compliance by Labrador. Furthermore, Labrador explained that the initial non-construction of the cul-de-sac was at petitioner Mapa's request, as he intended to purchase adjoining lots and enclose the area. The OAALA also noted that Mapa stopped payments in December 1976, which was premature as Labrador still had ample time under both the contract (two years) and PD 957 (one year from license issuance or two years from decree effectivity) to complete development. Therefore, Mapa's suspension of payments was improper, and Labrador was justified in rescinding the contracts due to Mapa's prolonged default.
Main Doctrine
The provisions of Presidential Decree No. 957, enacted after the execution of contracts to sell, cannot be given retrospective application to impose obligations not contemplated by the parties at the time of the contract's perfection. Furthermore, the doctrine of last antecedent is misapplied when used to separate enumerated facilities from the qualifying phrase specifying their offering in approved plans or advertisements.