G.R. No. L-16411; August 31, 1963
RODRIGO COLOSO, plaintiff-appellant, vs. DOMINGO DE JESUS, as Administrator of the Intestate Estate of the deceased Florentina N. Vda. de Jesus, LILIA DE JESUS-SEVILLA and HERMAN SEVILLA, defendants-appellees.

FACTS

On February 12, 1955, Rodrigo Coloso entered into a contract with Florentina N. Vda. de Jesus to manage and develop her 315-hectare land in Samal, Bataan. The agreement granted Coloso the right to cut trees, introduce improvements, and appoint tenants, with the fruits to be divided equally. Crucially, it included an option for Coloso to purchase the property for P60,000, exercisable within a ten-year period. Coloso entered the land and commenced clearing and planting operations.
Subsequently, a letter from individuals on the land prompted the Land Tenure Administration (LTA) to initiate steps for possible acquisition of the property for resale. The LTA held meetings with Coloso and Lilia de Jesus-Sevilla, representing her deceased mother’s estate, to negotiate a selling price. Coloso reduced his asking price from P3,000 to P770 per hectare, while Lilia de Jesus maintained a price of P2,000 per hectare. An LTA committee appraised the land at P700 per hectare, but no formal written offer to purchase at this price was ever made by the LTA to the estate. The negotiations ultimately did not result in a sale.

ISSUE

The core issue is whether Lilia de Jesus-Sevilla, by refusing to lower her asking price to match the LTA’s appraisal during negotiations, unlawfully obstructed the sale and thereby caused actionable damages to Coloso.

RULING

The Supreme Court affirmed the trial court’s dismissal of Coloso’s damage claims. The legal logic rests on the nature of the negotiations and Coloso’s rights at the time. The Court found that the LTA proceedings were merely preliminary negotiations to ascertain a possible selling price, not a definitive offer or a consummated sale. There was no formal offer from the LTA to purchase the property at P700 per hectare; thus, no binding agreement was ever reached between the estate and the government.
Critically, Coloso’s interest in the property at the time of the failed negotiations was merely an inchoate right—an unexercised option to purchase. He had not yet paid the P60,000 to become the owner. As the estate remained the legal owner, Lilia de Jesus-Sevilla, as an heir, had the absolute right to set the price at which she was willing to sell and to refuse any offer she deemed insufficient. The exercise of this proprietary right cannot be a source of legal liability for damages. Furthermore, Coloso failed to prove that Lilia’s price stance was the proximate cause of the negotiation’s failure, as no LTA official testified that a sale would have been finalized at P700. The Court upheld Coloso’s right to exercise his option under the original contract by paying P60,000 but correctly absolved the defendants of liability for damages.