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Siguenza vs.

Court of Appeals and Spouses Quimbo


J. Gutierrez, Jr. | July 16. 1985 | RMLPablo
RATIO
TOPIC: Other Cases
 In Castro vs. CA, the SC stressed the importance real purpose of the remedy of
appeal and ruled:
FACTS
o An appeal is an essential part of our judicial system. The SC advised
 Spouses Quimbo filed a complaint before CFI Cebu against petitioners Siguenza the courts to proceed with caution so as not to deprive a party the right
and Bert Osmeña for breach of contract and payment of damages: of appeal and that every party should be afforded the amplest
opportunity for appeal freed from the constraints of technicalities.
o They alleged that petitioners entered into a contract with them for the
sale of two lots purportedly owned by petitioners which were identified  The SC emphasized, however, that it allows the relaxation of rules on appeal
as Lot 1 and 2, Block 1, Phase II of Clarita Village. only when to do so would serve justice and in the exercise of equity jurisdiction.

o They discovered that petitioners had already sold the same lots to  Here, the petitioners’ delay in filing their appeal should not be strictly construed
Maningo both covered by TCTs. since on its face the appeal appears to be impressed with merit.

o Because of this double sale, spouses Quimbo demanded the return of ON THE MERITS OF THE CASE
their downpayment but the petitioners refused.
 The orders of the trial court ordering the petitioners to pay spouses Quimbo
o They claim that as a consequence of the deceit and misrepresentation 100,000 for compensatory damages is patently erroneous because no proof was
employed upon them by petitioners, they were prevented from presented to show that it actually suffered pecuniary loss in that amount.
constructing their house worth 100,000 on the lots which if constructed
at present would cost 300% than the original 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
 Petitioners admitted the sale but argued that the one responsible is Bert was presented to prove it.
Osmeña.
 Also, in Seavan vs. GTI Sportswear, the SC ruled that for damages under Article
o Osmeña admitted the sale of the lots to Maningo but countered that 2200 of the Civil Code to be recovered, the best evidence obtainable must be
such sale was only for the purpose of enabling Maningo to obtain a loan presented thus the bare assertion of spouses Quimbo about its losses are
from the GSIS. Since the loan did not materialize, the whole transaction inadequate if not speculative.
collapsed and during the proves of reverting the lots back, the spouses
Quimbo showed interest and deposited money though fully aware of the  As regards the awards of 50,000 moral damages and 25,000 exemplary
status of said lots. damages, the SC holds that such awards are far too excessive compared to the
actual losses. These amounts are without bases considering that spouses
o Osmeña also alleged that after the payment of the downpayment, no Quimbo had only paid a downpayment in the amount of 3,040 and had not yet
further installments were paid. occupied the property nor introduced any improvements thereon.

 The trial court ruled in favor of spouses Quimbo and ordered petitioners to pay  Finally, the SC noted that an excessive total of 188,650 in damages was
them 3,040 with interest,100,000 as compensation for pecuniary loss for failure to awarded in this case involving a downpayment of 3,040 on a full purchase price
construct their residential house, 5,610 as reimbursement, 50,000 as moral of 15,200 payable in installments.
damages, 25,000 as exemplary damages, and 5,000 as attorney’s fees and
costs. The CA affirmed the trial court.
DISPOSITIVE
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. 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
ISSUE WON spouses Siguenza lost the right to appeal – NO damages.
WON the amount of award damages were correct – NO