Civil Law,  Legally Yours

People’s Homesite v. CA

Civil Law. Sales. Perfected Sale of Contract. Conditional Obligations.
People’s Homesite & Housing Corp. v. Court of Appeals, Rizalino L. Mendoza, Adelaida R. Mendoza
G.R. No. L-61623, December 25, 1984
Aquino, J.:

FACTS:
Plaintiff People’s Homesite & Housing Corporation (PHHC) appealed from the ruling of the Court Appeals reversing the decision of the trial court affirming the withdrawal of the award of the plaintiff to respondent spouses of the subject lot.

The facts show that PHHC passed a resolution awarding Lot 4 of the consolidation-subdivision plan, containing 4,182.2 square meters at a price of twenty-one pesos per square meter, however, it is subject to the approval of the Quezon City Council and to the approval of the OEC (PHHC) Valuation Committee and higher authorities.

The city council disapproved the proposed consolidated subdivision plan and another plan was prepared and submitted to the city council for approval. This time, the council approved the plan with Lot 4 having a reduced area of 2,608.7 square meters. Subsequently, the PHHC board of directors recalled all the wards of lots to persons who failed to pay the deposit or down payment. The Mendozas never paid the price of the lot nor paid the initial deposit.

The Mendoza spouses asked for reconsideration of the withdrawal of the previous award to them of Lot 4 and for the cancellation of the re-award of said lot to third parties.

ISSUE:
Was there a perfected contract of sale by the plaintiff with respondent spouses which bounds the former to sell subject Lot 4?

HELD:
NO, there was no perfected sale of Lot 4. It was conditionally or contingently awarded to the Mendozas subject to the approval by the city council of the proposed consolidation-subdivision plan and the approval of the award by the valuation committee and higher authorities.

When the plan with the area of Lot 4 reduced to 2,608.7 square meters was approved, the Mendozas should have manifested in writing their acceptance of the award for the purchase of Lot 4 just to show that they were still interested in its purchase although the area was reduced and to obviate any doubt on the matter.

Therefore, the PHCC board of directors acted within its rights in withdrawing the tentative award.

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