Padrigon v. Palmero
REITERATIONFacts
The Antecedents: Respondent Benjamin E. Palmero (Palmero) filed a Complaint for Collection of Sum of Money with Damages against petitioner Rodolfo N. Padrigon (Padrigon). Palmero alleged that Padrigon offered to buy his property, including an ice plant, for P2,000,000.00, payable through eight developed lots plus P500,000.00 cash. They executed a Deed of Conditional Sale. Subsequently, Padrigon requested a change in the offer, proposing two bigger parcels of land plus P1,000,000.00 cash. The Deed of Conditional Sale was cancelled, and Padrigon executed an undated Deed of Absolute Sale for the two parcels of land and issued three postdated checks totaling P1,000,000.00. These checks were dishonored due to "account closed." Padrigon replaced one check for P200,000.00 but refused to replace the remaining two checks amounting to P800,000.00. Despite demands, Padrigon failed to pay the P800,000.00. Procedural History: Padrigon filed a Motion to Dismiss, which was denied by the RTC Makati. After several procedural maneuvers and petitions to the Court of Appeals (CA) assailing RTC orders, Padrigon was declared in default by the RTC Makati. Palmero presented evidence ex parte, and the RTC Makati rendered a Decision in favor of Palmero, ordering Padrigon to pay P800,000.00 plus interest, attorney's fees, and costs. The CA affirmed the RTC Decision. Padrigon then filed a Petition for Review on Certiorari before the Supreme Court. The Petition: Padrigon argued that Palmero's filing of a separate Complaint for Rescission of Deed of Absolute Sale before the RTC Daet constituted abandonment of the Complaint for Sum of Money before the RTC Makati, rendering the latter moot. He contended that if the Deed of Absolute Sale is rescinded, there is no basis for the collection of the sum of money, and affirming liability would lead to unjust enrichment.
Issue(s)
Whether the filing of a Complaint for Rescission of Deed of Absolute Sale constitutes abandonment of a prior Complaint for Collection of Sum of Money. Whether the Court of Appeals erred in affirming the Regional Trial Court's Decision ordering petitioner to pay respondent the amount of P800,000.00.
Ruling
The Supreme Court denied the petition, affirming the Court of Appeals' Decision with modification regarding the interest rates on the monetary awards. The Court held that the filing of the Complaint for Rescission did not constitute abandonment of the Complaint for Sum of Money, as the two actions pertained to different aspects of the transaction and no definitive ruling on rescission had yet been made.
Ratio Decidendi
On the issue of abandonment of action: The Court held that the filing of the Complaint for Rescission by respondent Palmero did not constitute abandonment of his Complaint for Sum of Money with Damages. The Court emphasized that there was no judgment rendered on the merits in the rescission case, meaning the basis for collection still existed. Furthermore, the Court noted that the Complaint for Rescission, as presented by Padrigon, appeared to focus on the sale of the lot (TCT No. T-38111), while the Complaint for Sum of Money was grounded on Padrigon's failure to make good his obligation for the sale of the building, ice plant, and machinery, and specifically on the dishonored checks. The Court found that Palmero's own narration in the Complaint for Rescission indicated two distinct transactions: one for the lot and another for the building, ice plant, and machinery. Therefore, the filing of the rescission case was not sufficient to establish abandonment of the collection case. On the merits of the collection case: The Court affirmed the findings of the CA that Palmero had sufficiently established his claim by preponderance of evidence. The existence of the Deed of Absolute Sale and the dishonored Prudential Bank checks (Nos. 040571 and 040572 for P200,000.00 and P600,000.00, respectively) were deemed sufficient proof of Padrigon's obligation to Palmero. Citing Pacheco v. Court of Appeals, the Court reiterated that a check constitutes evidence of indebtedness and is a veritable proof of an obligation. The Court also addressed Padrigon's argument of unjust enrichment, stating that it was premature to consider this as no ruling on rescission had been made, and any such legal repercussions should be raised before the RTC Daet where the rescission case was pending. The Court found that the collection case remained an actual controversy involving legally demandable and enforceable rights.
Main Doctrine
The filing of a subsequent complaint for rescission does not automatically constitute abandonment of a prior complaint for collection of sum of money, especially when the two actions pertain to different aspects of a complex transaction and no definitive ruling on rescission has been made.