GR 122544; (January, 2003) (Digest)
G.R. No. 122544 & 124741; January 28, 2003
REGINA P. DIZON, ET AL., petitioners, vs. COURT OF APPEALS and OVERLAND EXPRESS LINES, INC., respondents.
FACTS
The petitioners are co-owners of a property leased to private respondent Overland Express Lines, Inc., under a one-year contract with an option to purchase. After the lease expired, Overland remained in possession, creating an implied renewal on a monthly basis. In 1975, Overland delivered P300,000 to Alice Dizon, purportedly as partial payment for the property. Decades of litigation ensued, culminating in a 1999 Supreme Court decision ordering the execution of a 1982 judgment in favor of the petitioners for ejectment, but requiring them to refund the P300,000.
Private respondent filed multiple motions for reconsideration, leading the Court to set the case for oral argument on specific issues, including whether procedural rules should be suspended and whether a perfected contract of sale existed based on the P300,000 payment.
ISSUE
The core issue is whether a perfected contract of sale existed between the parties, thereby justifying the suspension of procedural rules to reopen the final 1999 judgment.
RULING
The Supreme Court denied the motion to suspend procedural rules and upheld its 1999 decision. The legal logic is twofold. First, on the substantive issue, no perfected contract of sale existed. The authority of an agent to sell real estate must be in writing pursuant to Article 1874 of the Civil Code. Alice Dizon, who received the P300,000, had no written authority from the co-owner petitioners to bind them to a sale. Her act could not create a valid contract, not even for the share of Fidela Dizon, in whose name the receipt was made but who also did not provide a written power of attorney.
Second, the implied renewal of the lease under Article 1670 of the Civil Code revived only terms germane to the right of enjoyment (e.g., rent, duration), not ancillary terms like an expired option to purchase. Overland’s belated attempt to exercise the option was therefore invalid. With no compelling substantive merit to private respondent’s claims, the Court found no strong reason to suspend its rules and prolong litigation. The 1999 judgment, having become final, must be enforced to end the controversy.