Mesina v. Garcia
REITERATIONFacts
The Antecedents: The underlying dispute concerns a Contract to Sell, executed on April 26, 1977, between the deceased Atty. Honorio Valisno Garcia and the deceased Felicisima Mesina, mother of the petitioners. The contract involved a 235-square-meter lot in Cabanatuan City, with a purchase price of P16,450.00, payable over seven years with interest. The contract stipulated that failure to pay five successive monthly installments would give Felicisima Mesina the right to rescind the contract, with paid installments recomputed as rent. The respondent, Gloria C. Garcia, is the wife of the deceased Atty. Honorio Valisno Garcia. Procedural History: The respondent, Gloria C. Garcia, claims to have fully paid the purchase price by February 7, 1984, but the petitioners refused to issue a Deed of Absolute Sale. Consequently, she filed a case for Specific Performance with Damages. The Regional Trial Court (RTC) of Cabanatuan City ruled in favor of the respondent, ordering the petitioners to issue the Deed of Absolute Sale and dismissing claims for damages and attorney's fees. The petitioners' motion for reconsideration was denied. They appealed to the Court of Appeals, which affirmed the RTC's decision. A subsequent motion for reconsideration by the petitioners was also denied, leading to the present petition. The Petition: The petitioners seek review of the Court of Appeals' decision via a Petition for Review on Certiorari under Rule 45 of the Rules of Civil Procedure. They argue that the respondent's cause of action had prescribed, that they are not estopped from denying acceptance of payments, and that the respondent failed to adduce competent evidence of full payment. The petitioners contend that the respondent, as a debtor, cannot benefit from the interruption of the prescriptive period under Article 1155 of the Civil Code, as the provision applies only to creditors making extrajudicial demands. They also assert that the respondent was not induced to believe she had fully paid and that her claims are unsubstantiated.
Issue(s)
Whether or not respondent’s cause of action had already prescribed. Whether or not petitioners are in estoppel. Whether or not the Court of Appeals failed to consider the fact that no competent evidence had been adduced by respondent tending to prove her cause of action.
Ruling
The Supreme Court denied the petition for review and affirmed the Decision of the Court of Appeals, which upheld the Decision of the RTC. The Court ruled that the respondent's cause of action had not prescribed, that the petitioners were estopped from denying acceptance of payments, and that the respondent had sufficiently proven full payment.
Ratio Decidendi
On the issue of prescription: The Court held that the respondent's cause of action had not prescribed. While the action was filed on January 20, 1997, and the full payment was made on February 7, 1984, the ten-year prescriptive period was interrupted by a series of written extrajudicial demands made by the respondent from April 19, 1986, until January 2, 1997. These demands included filing a complaint before the Housing and Land Use Regulatory Board (HLURB) in June 1986, executing an Affidavit of Adverse Claim on December 4, 1996, and sending a final demand letter on January 2, 1997. The Court clarified that Article 1155 of the Civil Code, which tolls the prescriptive period, applies to written extrajudicial demands made by the creditor. It reasoned that upon full payment, the respondent was no longer a debtor but had acquired a right to demand the execution of the Deed of Absolute Sale, thus making her the creditor in this context, and her demands qualified to interrupt prescription. The argument that only creditors can make demands to interrupt prescription was deemed indefensible as it would lead to injustice. On the issue of estoppel: The Court found that the petitioners were estopped from denying knowledge of and acceptance of the delayed payments made by the respondent. Evidence on record, including a letter dated April 10, 1986, from Engineer Danilo Angeles to petitioner Simeon Mesina, indicated that the title and Deed of Sale were ready for their signature, implying acceptance of payments. Furthermore, sworn statements made by the petitioners in their Petition for Review before the HLURB and in an Affidavit executed by petitioner Simeon Mesina affirmed that late payments were accepted, albeit with conditions regarding survey and titling expenses. These admissions, made under oath, clearly showed that petitioners accepted the payments and could not deny the fact of full payment. The respondent relied on these representations, making it prejudicial to allow the petitioners to deny them now. On the issue of failure to prove full payment: The Court held that the respondent had sufficiently proven full payment of the purchase price. The evidence presented, including receipts issued by petitioners' mother and their authorized collection agent, the Affidavit of Adverse Claim duly registered with the Register of Deeds, and the series of demand letters sent to petitioners without challenge, collectively established that the respondent had completed her obligation. These pieces of evidence, sustained by both the trial court and the appellate court, were deemed reliable and credible proofs of full payment, countering the petitioners' claim of unfounded assertions.
Main Doctrine
The series of written extrajudicial demands made by a party who has fully paid the purchase price of a property, even if considered a debtor in the initial contract, interrupts the prescriptive period for filing an action to compel the execution of the Deed of Absolute Sale. Furthermore, parties who made representations or admissions, whether through their own statements or those of their authorized agents, that late payments were accepted and considered full payment are estopped from later denying such acceptance and full payment.