BALUYOT v. CA July 22, 1999 Mendoza, J Luciano, Noel Christian Procedural case. Idk ano connection nya sa topic.
SUMMARY: Petitioners, residents of Brgy. Cruz-na-Ligas,
Diliman, QC, filed a complaint for specific performance and damages against UP and the QC Government. UP executed a Deed of Donation in favor of QC with the residents of the said barangay as beneficiaries. This is in relation to an ongoing dispute where the residents asserted ownership over a lot registered under UPs name. However, UP revoked the Deed of Donation for alleged non-compliance by QC of the conditions stated in the Deed. The Petitioners are seeking the enforcement of the Deed. UP and QC moved to dismiss the complaint for failure to state a cause of action. RTC denied but the CA reversed and dismissed the case. The SC held that the complaint states a cause of action as the petitioners were enforcing a stipulation pour autrui. DOCTRINE: Elements of a cause of action: (1) Right in favor of plaintiff by whatever means and under whatever law it arises or is created; (2) Obligation on the part of defendant to respect or not to violate such right; (3) Act or omission on the part of defendant in violation of the right of plaintiff or constituting breach of obligations to plaintiff. Requisites for stipulation pour autrui: (1) There must be a stipulation in favor of a third person; (2) Stipulation must be part, not the whole of the contract; (3) Contracting parties must have clearly and deliberately conferred a favor upon a third person, not a mere incidental benefit or interest; (4) Third person must have communicated his acceptance to the obligor before its revocation; (5) Neither of the contracting parties bears the legal representation or authorization of the third party.
FACTS: Petitioners Baluyot, et al. are residents of Brgy.
Cruz-na-Ligas, Diliman, QC and members of the Cruz-naLigas Homesite Association, a non-stock corporation composed of residents of Brgy. Cruz-na-Ligas. Petitioners filed a complaint for specific performance and damages against the University of the Philippines and Quezon City Government. ALLEGATIONS OF THE COMPLAINT: 1. That petitioners and their ascendants are in open, peaceful, adverse and continuous possession in the concept of owner since time immemorial of parcel of land (now Diliman) a. Members of the Association possessed the rest of the area 2. That claims of petitioners and the Association have been the subject of quasi-judicial proceedings and administrative investigations culminating in 2 Indorsements by the Bureau of Land and Office of the President a. Indorsements confirmed the rights of the bona fide residents to the parcel of land 3. Pursuant to the Indorsements, UP issued a Reply Indorsement a. UP Board of Regents approved donation of 9.2 hectares of the site directly to the residents; this was increased to 15.8 hectares b. But execution of the legal document failed because the residents demanded more than 15.8 hectares 4. Association proposed to accept and UP manifested in writing its consent to the intended donation to the Association for the benefit of the residents a. But UP backed out b. UP then resumed the donation thru QC Government 5. That there was a pending case (Im assuming its a land registration case since it is docketed as LRC No. 3151) and the Association amended its complaint:
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a. It demanded specific performance
b. Exclusion from the technical description of UPs TCT an area of about 42 hectares c. Association prayed for a writ of preliminary injunction to restrain UP from donating the area to QC 6. RTC issued a writ of preliminary injunction a. UP filed MR b. Association agreed to the lifting of the order granting the preliminary injunction after UP made an assurance in their MR that the donation to QC will be for the benefit of the residents of Cruz-naLigas 7. UP was not satisfied and demanded the dismissal of the case a. It argued that efforts to expedite the formalization of the Deed of Donation for the benefit of the residents should not only be preconditioned on the lifting of preliminary injunction but also the dismissal of the petition b. It filed another MR 8. Association filed a Comment to the new MR a. It manifested its willingness to the dismissal of the case PROVIDED that the area to be donated THRU QC government be subdivided into lots to be given to qualified residents together with TCTs without costs 9. With this manifestation, the RTC dismissed the case 10. UP then executed a Deed of Donation in favor of QC Government for the benefit of the qualified residents of Cruz-na-Ligas a. Under this Deed, 15.8379 hectares were ceded to QC Government b. Conditions imposed on QC (among others) (1) Within 18 months: (a) Remove the structures built on the boundaries (b) Relocation of the families
(c) Construction of fence on boundaries
(d) Construction of drainage canal (2) After 3 years, QC to transfer to qualified residents by way of donation the individual lots occupied by them subject to conditions imposed by QC 11. QC started complying with the conditions a. But UP failed to deliver the TCT covering the property to enable QC to register the Deed so that a corresponding TCT be issued under its name 12. After the lapse of 18 months, UP issued Admin Order No. 21 a. Declared the Deed of Donation revoked b. Ground: Failure of QC to comply with the conditions 13. That the revocation and reversion without judicial declaration is illegal and prejudicial to the rights of the plaintiffs who are bona fide residents of the Brgy. MOTION TO DISMISS: UP and QC filed a motion to dismiss on the ground that the complaint failed to state a cause of action RTC DECISION: It denied the Motion to Dismiss. It held that the complaint shows that it alleges facts entitling the plaintiffs to acquire ownership over the land by reason of laches. Trial on the merits is needed UP and QC filed a petition for certiorari before the CA CA DECISION: It set aside the RTC order and ordered the DISMISSAL of the case: 1. Complaint did not allege any claim for annulment of UPs title over the portion of land concerned or reconveyance to petitioners
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2. Alleged cause of action based on ownership of
petitioners was tantamount to a collateral attack on UPs title which is not allowed 3. No acquisition of ownership by laches Hence, this petition for certiorari ISSUES: 1. Whether the complaint states a cause of action. HELD: Yes, there is a cause of action I.
RTC erred in issuing its order
A. The RTC held: 1. The donation made by UP to QC has already been revoked so petitioners (for whose benefit the donation had been made) had no cause of action for specific performance 2. Motion to dismiss by respondents should be denied on the ground that UP was barred by laches from contesting petitioners right to remain in possession B. SC Ruling: 1. Laches is a defense against a registered owner suing to recover possession of the land registered in its name a. But UP is not the one suing in this case b. Petitioners are the one suing (1) Their suit is mainly to seek enforcement of the deed of donation made by UP to QC 2. Petitioners do not invoke laches. What they allege is adverse occupation from time immemorial a. They are claiming PRESCRIPTIVE acquisition b. But this cannot be since the land is a registered land which cannot be collaterally attacked
II. CA also erred in dismissing the petition on the ground
of failure to state a cause of action A. Elements of a cause of action: 1. Right in favor of plaintiff by whatever means and under whatever law it arises or is created 2. Obligation on the part of defendant to respect or not to violate such right 3. Act or omission on the part of defendant in violation of the right of plaintiff or constituting breach of obligations to plaintiff B. All the elements of a cause of action are present 1. Though the petitioners were not party to the Deed, they anchor their right to seek enforcement upon their allegation that they are intended beneficiaries of the donation a. Enforcement of a stipulation pour autrui (1) There must be a stipulation in favor of a third person; (2) Stipulation must be part, not the whole of the contract; (3) Contracting parties must have clearly and deliberately conferred a favor upon a third person, not a mere incidental benefit or interest; (4) Third person must have communicated his acceptance to the obligor before its revocation; (5) Neither of the contracting parties bears the legal representation or authorization of the third party. III. Respondents allegation that the complaint alleges inconsistent causes of action cannot stand A. Respondents: Petitioners seek the enforcement of the donation but at the same time seek the recovery of the land B. SC: These are not inconsistent but ALTERNATIVE causes of action 1. This is allowed under the rules
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DISPOSITIVE: CA DECISION REVERSED. REMANDED TO RTC
D. Johnson Willis v. Town of Trenton, North Carolina Joffree T. Leggett Charles C. Jones, Individually and as Member of Town Council Edward Eubanks, Individually and as Member of Town Council Edward Parker, Individually and as Former Member of Town Council Ann Brock, Individually as Former Member of Town Council Clifton Mills, Sr., Individually and as Former Member of Town Council Bob D. Henderson, Individually and as Former Member of Town Council James R. Franck, Individually and as Former Town Mayor Sheri M. Davenport, Individually and as Former Member of Town Council Harvey Rouse, Sr., Individually George W. Davenport, Individually and as Former Town Mayor C. Glenn Spivey, Individually and as Town Clerk Jesse J. Thomas, Individually Willard Odell Lewis, Individually and as a Member of Town Council Carol M. Hood, of the Will of James R. Hood, Deceased, D. Johnson Willis v. Town of Trenton, North Carolina Joffree T. Leggett Charles C. Jones, Individually and as Member of Town Council
People v. Gozo THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LORETA GOZO, Defendant-Appellant. G.R. No. L-36409 October 26, 1973 Public International Law