CD: Republic v. Philippine Resources Development Corporation

June 27, 2010 at 10:29 pm (1958, Case Digests) (, , )

REPUBLIC v. PHILIPPINE RESOURCES DEVELOPMENT CORPORATION
G.R. No. L-10141 January 31, 1958
Padilla, J.

Doctrine:
Article 1458 provides that the purchaser may pay “a price certain in money or its equivalent,” which means that the price need not be in money.

Facts:
The Bureau of Prisons instituted a complaint against Macario Apostol for the latter’s failure to pay the unpaid balance for logs purchased. Apostol, who was then the president of the respondent corporation, delivered goods belonging to the corporation and without the knowledge or consent of the stockholders thereof, to the Bureau of Prisons in an attempt to settle his personal debts with the latter entity. The corporation demanded the Bureau of Prisons for the return of the goods. Upon the refusal of the Bureau, the corporation filed a motion to intervene.

Issue:
Whether or not “price” is limited only to be paid in money

Held:
No. Article 1458 provides that the purchaser may pay “a price certain in money or its equivalent,” which means that they meant of the price need not be in money. In this case, the materials have been assessed and evaluated and their price equivalent in terms of money have been determined and that said materials for whatever price they have been assigned were considered as tokens of payment.

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CD: Leabres v. CA

June 26, 2010 at 11:13 am (1986, Case Digests) (, , )

LEABRES v. CA
G.R. No. L-41847 December 12, 1986
Paras, J.

Doctrine:
A receipt can neither be regarded as a contract of sale nor a promise to sell. In here, there is an absence of the essential requisites of a contract of sale.

Facts:
Plaintiff purchased a portion of a subdivision from the surviving husband of the deceased owner, evidenced by a receipt. The Philippine Trust Co relieved the surviving husband as administrator and advertised the sale of the subdivision. Since no adverse claim or interest over the subdivision or any portion thereof was ever presented by any person, the Philippine Trust Co. executed the Deed of Absolute Sale of the subdivision in favor of the Manotok Realty, Inc.. The deed was judicially approved and recorded immediately in the Register of Deeds which issued the corresponding Certificates of Title.

Issue:
Whether or not a receipt is a valid basis of a contract of sale

Held:
No. An examination of the receipt reveals that the same can neither be regarded as a contract of sale or a promise to sell. There was merely an acknowledgment of the sum of One Thousand Pesos (P1,000.00). The requisites of a valid Contract of Sale, namely 1) consent or meeting of the minds of the parties; 2) determinate subject matter; 3) price certain in money or its equivalent, are lacking in the said receipt.

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