Mato v. Court of Appeals
REITERATIONFacts
The Antecedents: Eulalia Marcita Taguba, as administratrix of the estate of the deceased Leonor Taguba, filed an action for specific performance with damages against Elvira Mato Vda. de Oñate. The case involved Lot No. 1571, a riceland. The deceased Leonor Taguba had allegedly bought the land from Elvira Mato Vda. de Oñate in 1976 for P5,000.00, payable in installments. Payments totaling P5,000.00 were made between January 20, 1976, and July 29, 1976. After full payment, the parties failed to reduce the contract to writing. Leonor Taguba died on December 30, 1976. The complaint was filed when Elvira Mato Vda. de Oñate refused to execute a public document of sale in favor of the deceased and her heirs. Procedural History: The trial court rejected Elvira Mato Vda. de Oñate's defense that she had a verbal loan from Leonor Taguba, secured by the land in dispute. On July 12, 1990, the trial court rendered judgment, declaring the agreement a contract to sell, ordering the defendants to execute a document of sale, and directing the plaintiff to prosecute money claims against the defendant's estate. Petitioners appealed to the Court of Appeals, arguing that the trial court erred in considering evidence (Exhibits "F," "F-1," "F-2," and "F-3") not formally offered. On December 13, 1993, the Court of Appeals affirmed the trial court's decision, holding that the exhibits, though not formally offered, were admissible as they were duly identified by recorded testimony and incorporated into the records. A motion for reconsideration was denied. The Petition: Petitioners filed a petition for review, assailing the Court of Appeals' decision for allegedly erring in considering documents not formally offered and for not ruling that specific performance could not be availed of due to the absence of a fixed purchase price.
Issue(s)
Whether evidence marked as exhibits but not formally offered can be considered by the court. Whether specific performance can be availed of when no fixed purchase price was agreed upon by the parties.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in toto. The Court held that evidence not formally offered may be admitted and considered by the trial court if it has been duly identified by recorded testimony and incorporated into the records of the case. The Court also found that the contract price of P5,000.00 was sufficiently established by unrebutted evidence and testimony, thus specific performance was a proper remedy.
Ratio Decidendi
On the admissibility of evidence not formally offered: The Court reiterated the rule that no evidence shall be considered which has not been formally offered, as provided in Section 35 (now Section 34) of Rule 132 of the Rules of Court. However, the Court noted that it had previously relaxed this rule in People v. Napat-a, citing People v. Mate. This relaxation allows evidence not formally offered to be admitted and considered provided two requirements are met: (1) the evidence must have been duly identified by testimony duly recorded, and (2) it must have been incorporated in the records of the case. In the present case, the Court found that Exhibits "F," "F-1," "F-2," and "F-3," which were receipts for payments made by the deceased Leonor Taguba to Elvira Mato Vda. de Oñate, satisfied these requisites. The exhibits were identified by the testimony of Eulalia Marcita Taguba, which was duly recorded, and the payments were admitted by the petitioners during pre-trial. Furthermore, the exhibits were incorporated into the records of the case. The Court also pointed to the vigorous cross-examination of the witness by the petitioners' counsel as indicative that the evidence was indeed considered part of the case. Therefore, the Court of Appeals did not err in admitting and considering these exhibits despite the lack of a formal offer. On the availability of specific performance: The Court found the petitioners' allegation that specific performance could not be availed of due to the absence of a fixed purchase price to be devoid of merit. The Court affirmed the findings of the lower courts that the contract price for the parcel of land in question was P5,000.00. This was supported by the evidence presented, including the receipts (Exhibits "F," "F-1," "F-2," and "F-3") and the testimony of Eulalia Marcita Taguba, which remained unrebutted. The trial court declared the agreement as a contract to sell, and the subsequent full payment of the agreed price of P5,000.00 entitled the buyer, Leonor Taguba, and her heirs to demand the execution of the corresponding deed of sale. The refusal of Elvira Mato Vda. de Oñate to execute the public document of sale after full payment constituted a breach of contract, making the remedy of specific performance appropriate.
Main Doctrine
Evidence not formally offered may be admitted and considered by the trial court provided it has been duly identified by testimony duly recorded and incorporated in the records of the case, thereby relaxing the strict requirement of formal offer of evidence.