GR 172446; (October, 2007) (Digest)
G.R. No. 172446 October 10, 2007
Alexander “Alex” Macasaet, petitioner, vs. R. Transport Corporation, respondent.
FACTS
R. Transport Corporation filed a Complaint for Recovery of Possession and Damages against Alexander Macasaet. The parties had executed a “Deed of Sale with Assumption of Mortgage” over four passenger buses, with Macasaet undertaking to pay P12,000,000.00 and assume an existing mortgage. R. Transport delivered two buses, but Macasaet failed to pay the purchase price. Prior to the deed, a “Special Trip Contract” was executed for a one-week lease of the buses. R. Transport obtained a writ of replevin and recovered the two buses. Macasaet claimed he had paid the full price and was the owner, counterclaiming for the buses’ return and delivery of the remaining units.
ISSUE
The core issue is whether Macasaet is liable to pay R. Transport for the use and income derived from the two passenger buses during their possession, and the related question of the perfection and efficacy of the Deed of Sale.
RULING
The Supreme Court denied the petition but modified the Court of Appeals’ decision. The Court held that the Deed of Sale was not a perfected contract of sale but merely a contract to sell. A contract of sale is perfected at the moment there is a meeting of the minds upon the thing and the price. Here, the deed was conditional upon Macasaet’s payment of the purchase price and his assumption of the mortgage obligation. Since Macasaet failed to pay the price, the suspensive condition did not occur, and ownership never transferred to him. Consequently, R. Transport retained ownership and the right to the fruits of the property. While the Special Trip Contract had expired, Macasaet’s continued use of the buses constituted unjust enrichment. He is liable to pay reasonable compensation for their use. The Court fixed this at P10,000.00 per bus per day, as stipulated in the expired lease, for the period from October 16, 1995, to January 16, 1996, deducting the P120,000.00 already remitted, totaling P1,460,000.00. The Court also ordered the payment of legal interest and directed the assessment of additional filing fees based on the awarded amount.