Mancol v. Development Bank of the Philippines
REITERATIONFacts
The Antecedents: Respondent Development Bank of the Philippines (DBP) offered for sale a residential lot with a two-storey building. Petitioner Fernando Mancol, Jr., through his father Fernando Mancol, Sr. acting as his attorney-in-fact, participated in the negotiated sale. Mancol, Sr. signed the offer to purchase and related documents, and made an initial payment. DBP subsequently issued a Deed of Absolute Sale in favor of the petitioner after the full payment was made. The petitioner also deposited funds for capital gains tax (CGT) and documentary stamp tax (DST). However, DBP later reneged on alleged verbal agreements to arrange the transfer of title, including tax payments, and to remove occupants from the property. DBP returned the petitioner's deposit for taxes and pertinent sale documents, asserting no obligation to handle title transfer or eject occupants. Procedural History: The petitioner filed a complaint for damages against DBP for breach of contract, seeking reimbursement for taxes, damages, and attorney's fees. The Regional Trial Court (RTC) initially ruled in favor of the petitioner, ordering DBP to return the tax deposit and pay surcharges and attorney's fees. However, upon DBP's motion for reconsideration, the RTC dismissed the petitioner's complaint, modifying its previous order only to direct DBP to return the P99,450.00 with interest. Both parties appealed to the Court of Appeals (CA). The CA denied both appeals, affirming the RTC's orders. The petitioner then filed the instant petition for review on certiorari. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court seeks to reverse the Court of Appeals' decision affirming the RTC's dismissal of the petitioner's complaint. The petitioner argues that the testimonies of his witnesses, Villanueva and Mancol, Sr., were based on personal knowledge and not hearsay, and that these testimonies sufficiently established the existence and validity of a subsequent oral agreement with DBP to arrange the title transfer and remove occupants. The petitioner further contends that undisputed evidence supports this oral agreement, and that ignoring it violates his due process rights. Finally, he asserts entitlement to moral and exemplary damages, attorney's fees, and costs of suit.
Issue(s)
Whether the testimonies of Villanueva and Mancol, Sr. are admissible and have probative value to establish the alleged contemporaneous verbal agreement. Whether the alleged verbal agreement to arrange the transfer of title and eject occupants is valid and enforceable, notwithstanding the written Deed of Absolute Sale and Negotiated Sale Rules and Procedures. Whether petitioner is entitled to moral and exemplary damages, attorney's fees, and costs of suit.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the admissibility and probative value of testimonies: The Court reiterated that while the failure to object to the admissibility of evidence waives the protection of the parol evidence rule, admissibility does not automatically confer probative value. Hearsay evidence, which is testimony based on what a witness learned from others rather than personal knowledge, lacks the weight to establish the truth of a disputed fact. Villanueva's testimony was hearsay as he had no personal knowledge of the alleged verbal agreement between petitioner and DBP; he only testified about being ordered to deliver documents. Mancol, Sr.'s testimony was also deemed hearsay because, despite being the petitioner's representative, there was no clear evidence that he personally entered into the verbal agreement with DBP officials or witnessed its perfection. The SPA granted to Mancol, Sr. was limited to representing and negotiating the bid and signing necessary documents, not to enter into subsequent verbal agreements. On the validity and enforceability of the verbal agreement: The Court found that even if the testimonies were admitted as an exception to the parol evidence rule, they lacked probative value to prove the alleged verbal agreement. The SPA did not grant Mancol, Sr. the authority to enter into a verbal agreement with DBP regarding the transfer of title and removal of occupants. The Court emphasized that powers granted in an SPA must be strictly construed and are limited to those expressly specified. Therefore, any verbal agreement outside the scope of the SPA, and not supported by clear and convincing evidence, could not be enforced against DBP. On damages and attorney's fees: Since the Court found no breach of contract due to the lack of a valid and enforceable verbal agreement, the claim for damages and attorney's fees was consequently denied. The Court reiterated that it is not a trier of facts and will not disturb the findings of the CA, especially when they coincide with the RTC's findings.
Main Doctrine
While the failure to object to the admissibility of evidence waives the protection of the parol evidence rule, admissibility does not equate to probative value. Hearsay evidence, even if admitted without objection, lacks the weight to establish the truth of a disputed fact.