GR 169578; (November, 2006) (Digest)
G.R. No. 169578 ; November 30, 2006
TERESITA DIO, Petitioner, vs. ST. FERDINAND MEMORIAL PARK, INC. and MILDRED F. TANTOCO, Respondents.
FACTS
Petitioner Teresita Dio purchased a memorial lot on installment from respondent St. Ferdinand Memorial Park, Inc. (SFMPI) in 1973. The Pre-Need Purchase Agreement and the subsequent Deed of Sale incorporated SFMPI’s Rules and Regulations, which included Rule 69. This rule stipulated that all mausoleum construction must be undertaken by the park’s personnel, though lot owners could submit their own designs subject to park standards. In 1986, Dio decided to build a mausoleum, prepared plans through a private contractor at an estimated cost of ₱60,000, and sought SFMPI’s approval. Respondent Mildred Tantoco, SFMPI’s president, approved the design but insisted that construction be done by SFMPI at a minimum cost of ₱100,000, citing Rule 69.
Dio filed a Complaint for Injunction with Damages before the Regional Trial Court (RTC), arguing she was unaware of Rule 69 and that the mandated construction cost was unconscionable. The RTC ruled in favor of Dio, declaring Rule 69 invalid and enjoining its enforcement. The Court of Appeals (CA) reversed the RTC, holding that the rule was valid and binding on Dio. The CA found that the contracts Dio signed expressly made her purchase subject to SFMPI’s rules, which she was presumed to know. Dio’s petition for review elevated the case to the Supreme Court.
ISSUE
Whether Rule 69 of SFMPI’s Rules and Regulations, which requires lot owners to use park personnel for mausoleum construction, is valid and binding upon petitioner Teresita Dio.
RULING
The Supreme Court denied the petition and affirmed the CA decision, upholding the validity of Rule 69. The Court’s legal logic centered on contract law principles. Dio expressly agreed in the Pre-Need Purchase Agreement to abide by SFMPI’s rules and regulations. The Deed of Sale further reiterated that her ownership was subject to these rules. By signing these contracts without protest, Dio was conclusively presumed to know their contents and assented to all stipulated terms, including Rule 69. The Court emphasized that one who signs a contract is presumed to have done so with full knowledge and consent.
The Court rejected Dio’s claim of being unaware of the rule, as ignorance of a contract’s stipulations does not negate consent or relieve a party from its binding effects. It also found no basis for the claim that the ₱100,000 minimum cost was unconscionable, as this amount was presented as an estimate commensurate with the approved plan and materials, not as a fixed, oppressive fee. The rule was a pre-existing, integral part of the contractual package governing the memorial park’s orderly administration and aesthetic uniformity. Therefore, SFMPI was within its rights to enforce the rule, and Dio was legally bound by her contractual commitment.