People’s Homesite & Housing Corporation v.

CA o BEFORE it could be acted upon, the spouses filed the instant action
Conditional Contract of Sale | Dec. 26, 1984 | J. Aquino for specific performance and damages.
 Trial court sustained withdrawal of the award. Appellate court, on appeal of
Nature of Case: Appeal
Mendozas, reversed the decision and declared void the re0award of Lot 4
Digest maker: Miranda, Martin
and the deeds of sale, directing PHHC to sell Lot 4 to the Mendozas at the
SUMMARY: The Mendozas appealed against the sale of Lot 4 to five re-awardees
agreed upon area and price (See: Feb. 25, 1964). PHHC appealed to the SC.
after the PHHC board of directors withdrew their award. The Mendozas failed to
pay the intial deposit at the time, resulting in the withdrawal of the award. The
ISSUE/S & RATIO:
Supreme Court ruled that there was no perfected sale of Lot 4 to the Mendozas,
W/N there was a perfected sale of Lot 4, with the reduced area, to the
and therefore no cause of action, since there was no meeting of the minds or
Mendozas which they can enforce against the PHHC by an action for
manifestation of intent by the Mendozas to purchase Lot 4 in its reduced area and
specific performance
price.
DOCTRINE: The contract of sale is perfected at the moment there is a meeting of
No. There was no perfected sale of Lot 4, as it was conditionally or contingently
minds upon the thing which is the object of the contract and upon the price. From
awarded to the Mendozas subject to the approval by the city council. The contract of
that moment, the parties may reciprocally demand performance, subject to the law
sale is perfected at the moment there is a meeting of minds upon the thing which is
governing the form of contracts. In conditional obligations, the acquisition of
the object of the contract and upon the price. From that moment, the parties may
rights, as well as the extinguishment or loss of those already acquired, shall
reciprocally demand performance, subject to the law governing the form of
depend upon the happening of the event which constitutes the condition.
contracts1. In conditional obligations, the acquisition of rights, as well as the
extinguishment or loss of those already acquired, shall depend upon the happening
FACTS: of the event which constitutes the condition.2
 Feb. 18, 1960: PHHC board of directors passed Reso. No. 513, which stated
“that subject to the approval of the QC City Council of the...Consolidation There was no meeting of the minds on the purchase of Lot 4. When the plan with the
Subdivision Plan, Lot 4, containing 4,182.2 sq. meters be, as it is hereby area of Lot 4 was reduced and approved, the Mendozas should have manifested in
awarded to Sps. Rizalino Mendoza and Adelaida Mendoza, at a price of writing their acceptance of the award for the purchase of Lot 4 just to show that they
P21.00 per sq. meter….[T]his award shall be subject to the approval of the were still interested, which they did not do. The PHHC board of directors acted
OEC (PHHC) Valuation Committee and higher authorities.” within its rights in withdrawing the tentative award.
 Aug. 20, 1961: City council disapproved the proposed consolidation
subdivision plan, where the spouses were advised by registered mail of the RULING:
disapproval of the plan. WHEREFORE, the decision of the Appellate Court is reversed and set
 Feb. 25, 1964: After preparation of another subdivision plan, this revised aside and the judgment of the trial court is affirmed. No costs.
plan including Lot 4, with a reduced area of 2608.7 sq. m, was approved by
the city council.
Notes:
 April 26, 1965: PHHC board of directors passed a resolution recalling all The case of Lapinig v. CA, 115 SCRA 213 is not in point because the
awards of lots to persons who failed to pay the deposit (20%) or down
payment for the lots awarded to them, which the Mendozas never paid. awardee in that case applied for the purchase of the lot, paid the 10%
 Oct. 18, 1965: PHHC board of directors passed Reso. No. 218, withdrawing
deposit and a conditional contract to sell was executed in his favor.
the tentative award of Lot 4 to the Mendozas under Reso. No. 513, and The PHHC could not re-award that lot to another person.
awarding Lot 4 jointly and in equal shares to Miguela Sto. Domingo,
Enrique Esteban, Virgilio Pinzon, Leonardo Redublo, and Jose Fernandez.
Prices would be the same as those of the adjoining lots.
o Five awardees made the initial deposit, and the corresponding
deeds of sale were executed in their favor.
 March 16, 1966: Mendozas asked for reconsideration of the previous award
of Lot 4 to them and for the cancellation of the re-award of the lot to the five
awardees.
1 Art. 1475, NCC
2 Art. 1181, NCC