Spouses Del Rosario v. Romualdez
REITERATIONFacts
The Antecedents: Benita Quiogue de V. del Rosario, the petitioner, owned five school buildings and their lots in Manila. The City of Manila was renting these properties for school purposes. In late 1923, the city expressed a desire to purchase these properties. An agreement was reached for the city to buy the properties for their assessed value of P346,683.62, with an initial payment of half the price and the balance payable in three equal annual installments with interest. Procedural History: Following the agreement, Ordinance No. 1169 was passed and approved, authorizing the acquisition and appropriating funds for the initial payment. The petitioner communicated her acceptance of the terms to the Municipal Board. However, the respondent Mayor Miguel Romualdez refused to accept the deed of conveyance and make the initial payment, citing a lack of funds and unsuitability of the properties for school use. Subsequently, Ordinance No. 1169 was repealed by Ordinance No. 1196, which the petitioner also challenged. The Petition: This case is an original petition for a writ of mandamus filed by Benita Quiogue de V. del Rosario, seeking to compel the Mayor of Manila to accept the deed of conveyance, make the initial payment, and issue obligations for the balance of the purchase price as per the alleged contract. The respondent demurred to the amended petition. The Supreme Court considered whether mandamus was the appropriate remedy for enforcing a private contract, noting that the petitioner had an adequate remedy at law through an original action in the Court of First Instance.
Issue(s)
Whether a writ of mandamus is the proper remedy to compel a municipal mayor to accept a deed of conveyance and make payments pursuant to an alleged contract of sale. Whether the petitioner has an adequate remedy at law for the enforcement of the alleged contract.
Ruling
The demurrer to the petition is sustained, and the petition is dismissed unless amended within five days to show a sufficient cause of action.
Ratio Decidendi
On whether a writ of mandamus is the proper remedy: The Court held that mandamus is not the appropriate remedy to enforce the performance of private contracts. The petitioner's rights, if any, are derived from her contract with the city. Mandamus is a special remedy designed to compel the performance of a duty enjoined by law, not to enforce contractual obligations between private parties or between a private party and a municipality based on a contract. The case presented disputed issues of fact and involved the enforcement of a private contract, which are outside the scope of mandamus. On whether the petitioner has an adequate remedy at law: The Court found that the petitioner has an adequate remedy at law. If a valid contract exists and has been breached by the city, the petitioner can pursue an original action in the Court of First Instance to compel payment or to recover damages for breach of contract. The existence of this adequate legal remedy is fatal to the right to seek relief through a writ of mandamus. The Court noted that the situation presented grounds for a complicated controversy over specific performance, which is not suitable for a mandamus proceeding.
Main Doctrine
The writ of mandamus is not an appropriate remedy to enforce the performance of private contracts, especially when there are disputed issues of fact or when an adequate remedy at law, such as an action for specific performance or damages, exists.