G.R. No. 30668 , August 28, 1929
SABAS BUSTAMANTE, ET AL., plaintiffs-appellants, vs. JOSE M. RATO Y TUASON, ET AL., defendants-appellees.

FACTS

This case originated from a long-standing dispute over parcels of land within the Hacienda Maysilo. In a prior decision ( G.R. No. 22510 ), the Supreme Court absolved the defendants from liability but reserved the plaintiffs’ right to file a new action if they could prove they had a contract to purchase land within the hacienda. Pursuant to this reservation, the plaintiffs (Sabas Bustamante et al.) filed the present action for specific performance to compel the defendants (owners of Hacienda Maysilo) to execute deeds conveying certain lots to them. The plaintiffs were in possession of the land. The defendants denied the plaintiffs’ claim and filed a cross-complaint for recovery of possession and compensation for use and occupation. The trial court ruled in favor of the defendants, absolving them from the complaint and ordering the plaintiffs to surrender possession and pay compensation for use and occupation. The plaintiffs appealed.

ISSUE

Whether the plaintiffs have established an enforceable contract for the purchase of the land, entitling them to specific performance.

RULING

No. The Supreme Court affirmed the trial court’s decision. The plaintiffs failed to prove the existence of an enforceable contract for purchase. Their claim was based on a receipt (Exhibit F) issued by Tomas Arguelles, an authorized agent of the defendants, acknowledging payment from Apolinario Baltazar for five parcels of land. However, the obligation under the receipt was personal to Baltazar, not to the plaintiffs, and there was no proof that the defendants knew Baltazar was acting in a representative capacity for the plaintiffs. Moreover, the defendants had already fully satisfied their obligation to Baltazar by conveying parcels to him, which he accepted. Consequently, there was no privity of contract between the plaintiffs and the defendants. Since the action for specific performance failed, the defendants were entitled under their cross-complaint to recover possession and compensation for the plaintiffs’ use and occupation of the land. The appealed judgment was affirmed, with costs against the appellants.