Asis v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Engracio de Asis agreed to sell a parcel of land with improvements to respondent Jose B. Feliciano for P10,018.40. The vendee made an initial payment and monthly installments until September 9, 1943, when the balance of P2,934.84, plus P45.36 for insurance premiums, was paid. Subsequently, the vendor executed a deed of sale, a transfer certificate of title was issued in the vendee's name, and the sale was registered. Procedural History: On May 31, 1945, the vendor filed a suit to annul the sale, alleging threat, intimidation, or duress. The Court of First Instance of Manila dismissed the complaint, finding no evidence of coercion. The Court of Appeals affirmed this judgment. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, arguing that the Court of Appeals failed to pass upon two issues: (1) that the trial court's judgment was contrary to the regulations of the Hague Conventions of 1907, and (2) that the payment of the balance by the vendee using Japanese military or war notes impaired his constitutional rights.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's dismissal of the complaint for annulment of sale. Whether the payment made in Japanese military or war notes, if true, vitiated the consent of the vendor. Whether the judgment of the trial court was contrary to the regulations of the Hague Conventions of 1907.
Ruling
The Supreme Court affirmed the judgment of the Court of Appeals. The petition for certiorari was denied, and the decision of the Court of Appeals was upheld without costs.
Ratio Decidendi
On Issue 1 (Affirmance of Dismissal): The Supreme Court held that the factual findings of the Court of Appeals, which affirmed the trial court's conclusion that the vendee did not resort to threat, intimidation, or duress, are binding and cannot be disturbed. The Court noted that the vendee paid the balance only after receiving a statement of account from the vendor, the vendor instructed his own notary to prepare the deed, and the vendor voluntarily sent the deed and title to the vendee. These facts demonstrated the voluntary nature of the transaction, negating the claim of vitiated consent. On Issue 2 (Payment in War Notes): Even assuming, arguendo, that the payment was made in Japanese military or war notes and that these notes were not legal tender, the Supreme Court found that the vendor could not question the payment. The lower courts found that the vendor had required the vendee to settle his accounts and voluntarily accepted the payment. Having voluntarily accepted the payment and executed the deed of sale, the vendor was estopped from later assailing the transaction on the ground of the payment method. The vendor had the option to refuse the payment and the execution of the deed. On Issue 3 (Hague Conventions): The Court found it unnecessary to rule on whether the judgment was contrary to the Hague Conventions of 1907. Given the factual findings that the vendor voluntarily accepted the payment and executed the deed of sale, any potential issues regarding the legality of the currency or the applicability of international regulations became moot. The voluntary nature of the vendor's actions precluded him from raising these arguments after the fact.
Main Doctrine
The Supreme Court is bound by the factual findings of the Court of Appeals, especially when such findings are supported by substantial evidence. Furthermore, a party who voluntarily accepts payment and proceeds with the execution of a deed of sale, despite potential issues with the currency used, may be estopped from later questioning the validity of the transaction on that basis. The principle of volenti non fit injuria (to a willing person, injury is not done) applies, as the vendor had the option to refuse the payment and the deed execution.