Siguenza vs.
Court of Appeals and Spouses Quimbo
J. Gutierrez, Jr. | July 16. 1985 | RMLPablo
TOPIC: Other Cases
FACTS
 Spouses Quimbo filed a complaint before CFI Cebu against petitioners Siguenza
and Bert Osmeña for breach of contract and payment of damages:
o They alleged that petitioners entered into a contract with them for the
sale of two lots purportedly owned by petitioners which were identified
as Lot 1 and 2, Block 1, Phase II of Clarita Village.
o They discovered that petitioners had already sold the same lots to
Maningo both covered by TCTs.
o Because of this double sale, spouses Quimbo demanded the return of
their downpayment but the petitioners refused.
o They claim that as a consequence of the deceit and misrepresentation
employed upon them by petitioners, they were prevented from
constructing their house worth 100,000 on the lots which if constructed
at present would cost 300% than the original amount.
 Petitioners admitted the sale but argued that the one responsible is Bert
Osmeña.
o Osmeña admitted the sale of the lots to Maningo but countered that
such sale was only for the purpose of enabling Maningo to obtain a loan
from the GSIS. Since the loan did not materialize, the whole transaction
collapsed and during the proves of reverting the lots back, the spouses
Quimbo showed interest and deposited money though fully aware of the
status of said lots.
o Osmeña also alleged that after the payment of the downpayment, no
further installments were paid.
 The trial court ruled in favor of spouses Quimbo and ordered petitioners to pay
them 3,040 with interest,100,000 as compensation for pecuniary loss for failure to
construct their residential house, 5,610 as reimbursement, 50,000 as moral
damages, 25,000 as exemplary damages, and 5,000 as attorney’s fees and
costs. The CA affirmed the trial court.
o The CA ruled that the spouses Quimbo’s appeal was out of order since
their record on appeal was filed 13 days late from the deadline.
ISSUE WON spouses Siguenza lost the right to appeal – NO
WON the amount of award damages were correct – NO
RATIO
 In Castro vs. CA, the SC stressed the importance real purpose of the remedy of
appeal and ruled:
o An appeal is an essential part of our judicial system. The SC advised
the courts to proceed with caution so as not to deprive a party the right
of appeal and that every party should be afforded the amplest
opportunity for appeal freed from the constraints of technicalities.
 The SC emphasized, however, that it allows the relaxation of rules on appeal
only when to do so would serve justice and in the exercise of equity jurisdiction.
 Here, the petitioners’ delay in filing their appeal should not be strictly construed
since on its face the appeal appears to be impressed with merit.
ON THE MERITS OF THE CASE
 The orders of the trial court ordering the petitioners to pay spouses Quimbo
100,000 for compensatory damages is patently erroneous because no proof was
presented to show that it actually suffered pecuniary loss in that amount.
 In the case of Sy vs. CA, the SC ruled that an alleged loss of income is not
recoverable for being speculative as no receipt or any evidence on the matter
was presented to prove it.
 Also, in Seavan vs. GTI Sportswear, the SC ruled that for damages under Article
2200 of the Civil Code to be recovered, the best evidence obtainable must be
presented thus the bare assertion of spouses Quimbo about its losses are
inadequate if not speculative.
 As regards the awards of 50,000 moral damages and 25,000 exemplary
damages, the SC holds that such awards are far too excessive compared to the
actual losses. These amounts are without bases considering that spouses
Quimbo had only paid a downpayment in the amount of 3,040 and had not yet
occupied the property nor introduced any improvements thereon.
 Finally, the SC noted that an excessive total of 188,650 in damages was
awarded in this case involving a downpayment of 3,040 on a full purchase price
of 15,200 payable in installments.
DISPOSITIVE
The SC ruled that the petitioners are liable only for the amount of
 3,040 with legal interest, 10,000 moral damages, 5,000 exemplary damages, and
another 5,000 attorney’s fees. Petitioners are not liable for compensatory
damages.