G.R. No. 205810 , September 9, 2020
Estate of Valeriano C. Bueno and Genoveva I. Bueno, represented by Valeriano I. Bueno, Jr. and Susan I. Bueno, Petitioners, vs. Estate of Atty. Eduardo M. Peralta, Sr. and Luz B. Peralta, represented by Dr. Edgardo B. Peralta, Respondents.

FACTS

In 1957, Spouses Valeriano and Genoveva Bueno engaged Atty. Eduardo M. Peralta, Sr. as their legal counsel. In 1960, the Spouses Bueno gave Atty. Peralta a property located at Magistrado Villamor Street, Manila, as partial consideration for his professional services. Atty. Peralta and his family occupied the property starting January 1962, introduced substantial improvements, and paid real property taxes. Atty. Peralta requested a deed of conveyance, but due to encumbrances on the property, Bueno only provided a copy of the title and had Atty. Peralta pay the taxes. Atty. Peralta passed away in 1983. In 1990, Dr. Edgardo Peralta, representing the Estate of Peralta, requested the deed of conveyance from the Spouses Bueno, who instead demanded surrender of the property. The Estate of Peralta filed a complaint for specific performance. The Spouses Bueno argued the claim was unenforceable under the Statute of Frauds and that specific performance was impossible due to encumbrances. The Regional Trial Court (RTC) dismissed the complaint, finding no perfected contract and that the action had prescribed. The Court of Appeals (CA) reversed the RTC, ruling that a perfected innominate contract (facio ut des) existed, partially performed by both parties, removing it from the Statute of Frauds, and ordered the Estate of Bueno to execute the deed of conveyance.

ISSUE

Whether the Court of Appeals correctly ruled that a valid and enforceable contract existed between the parties for the conveyance of the subject property in exchange for Atty. Peralta’s legal services, which was partially performed and thus not barred by the Statute of Frauds or prescription.

RULING

Yes. The Supreme Court affirmed the CA decision. The agreement between Bueno and Atty. Peralta was a valid innominate contract of facio ut des (I render service, you give the property). Atty. Peralta rendered continuous legal services, and Bueno partially performed by delivering possession of the property. This partial performance took the agreement out of the scope of the Statute of Frauds, which applies only to executory contracts. The action had not prescribed because the cause of action to demand formal conveyance accrued only upon Atty. Peralta’s retirement in 1980, and the complaint was filed in 1996, well within the 10-year prescriptive period for actions upon a written contract. The Estate of Bueno was ordered to execute the deed of conveyance in favor of the Estate of Peralta.