Persons I Prime Town Property Group, Inc. (PPGI) and E. Ganzon Inc.

A.Y. 1920 — Atty. Katrina Legarda were the joint developers of Kiener Hills Mactan Condominium
Project (Kiener Hills). In 1997, Uy spouses entered into a Contract
TOPIC Stare decisis to sell with PPGI for a unit at Kiener Hills. In 1998, PPGI and
UCPB executed the ff:
CASE NO. G.R. No. 204039 1. Memorandum of Agreement; and
2. Sale Receivables and Assignment of Rights and Interest.
CASE NAME UCPB v Uy
By virtue of the agreements, PPGI transferred the right to collect the
PONENTE Martires, J. receivables of the buyers, which including the Uy spouses, of units
in Kiener Hills. On 18 April 2006, respondents filed a complaint
PETITIONER United Coconut Planters Bank (UCPB)
against PPGI and UCPB at the Housing and Land Use REgulatory
RESPONDENT Walter Uy, Lily Uy (Uy spouses) Board Regional Office (HLURB RO). They claimed that PPGI
failed to complete the construction of units their at Kiener Hills.
TYPE OF Petition for review on certiorari HLURB RO, on 29 Nov 2006, found that the respondents are
CASE
entitled to a refund in view of PPGI’s failure to complete the
MEMBER Jaydison A. Aniwer construction. It also found that UCPB is not solidarily liable with
PPGI because only the accounts receivables were conveyed to
Issue: UCPB, not the entire condo project. HLURB RO suspended the
I. Whether the CA made an error when it misconstrued the proceedings thereof as to PPGI on the account of its corporate
applicability to the instant case of the final and executory rehabilitation.
decision UCPB v O’Halloran under the principle of stare Respondents then appealed before the HLURB Board. The board
decisis. reversed the ruling; they found UCPB solidarily liable as it is
II. Whether the CA grievously erred in ruling that UCPB is indicated in the MOA between UCPB and PPGI. UCPB was bound
liable to the respondents for the amount the respondents did to refund the payments made.
not pay the bank and which UCPB did not receive. UCPB appealed before the HLURB Office of the President (?).
Facts: HLURB OP affirmed the decision of the board.
UCPB appealed before the CA. CA affirmed the decision on with
modification:
1. UCPB is not solidarily liable. CA limited UCPB’s liability to
the amount paid upon UCPB’s assumption as the party
entitled to receive payments when MOA and AIR were
made. ​CA noted the pronouncements of the CA in UCPB
v O’Halloran. ​It involved similar facts.
UCPB moved for reconsideration but was denied. UCPB then filed a
petition for review on certiorari with the SC.
Ratio Decidendi:
I. Whether the CA made an error when it misconstrued the
applicability to the instant case of the final and executory
decision UCPB v O’Halloran under the principle of stare
decisis.
The doctrine of ​stare decisis entrenched in Article 8 of the Civil
Code is explained in De Mesa v Pepsi-Cola Products Phils. Inc​. It
only becomes operative when judicial precedents are set by
pronouncements of the SC, to the exclusion of lower courts. At
most, decisions of the lower courts only have a persuasive effect.
Thus, CA misapplied the doctrine of stare decisis.
II. Whether the CA grievously erred in ruling that UCPB is
liable to the respondents for the amount the respondents did
not pay the bank and which UCPB did not receive.
The CA did not err in its ruling. ​In ​Spouses Choi v. UCPB (Spouses
Choi),t​ he Court had definitely ruled on UCPB 's liability to the
purchasers of Kiener Hills:
The Agreement conveys the straightforward intention
of Primetown to "sell, assign, transfer, convey and set over"
to UCPB the receivables, rights, titles, interests and
participation over the units covered by the contract to sell. It
explicitly excluded any and all liabilities and obligations,
which Primetown assumed under the contracts to sell. The
intention to exclude Primetown's liabilities and obligations is
further shown by Primetown's subsequent letters to the
buyers, which stated that "this payment arrangement shall in
no way cause any amendment of the other terms and
conditions, nor the cancellation of the Contract to Sell you
have executed with [Primetown]."
Dispositive Portion:
WHEREFORE, the decision of the CA is AFFIRMED with
MODIFICATION. Petitioner UCPB shall pay the amount of
₱157,757.82 to Spouses Walter and Lily Uy, with legal interest at
six percent (6%) ​per annum​, without prejudice to any action which
the parties may have against PPGI.
Doctrine/Precedent:
Stare decisis​ applies only to cases decided by the Supreme Court.
Relevant Laws/Jurisprudence:
- Article 8 of the Civil Code
- De Mesa v Pepsi Cola Products Phils. Inc. 504 Phil. 521
(2005)