GR L 30201; (July, 1982) (Digest)
G.R. No. L-30201 July 20, 1982
Carmen P. Urbano, petitioner, vs. J. M. Tuason & Co., Inc., ET AL., respondents.
FACTS
Petitioner Carmen P. Urbano, representing plaintiffs-appellants, filed an action for specific performance against J. M. Tuason & Co., Inc. They sought to compel Tuason to sell them a 1,500-square-meter lot at P7.00 per square meter, crediting a P4,500 payment made to Pedro Deudor. Their claim originated from a 1949 sale by Deudor to Tomasa F. de Salanga, their predecessor. Their right to demand a sale from Tuason was based on a 1953 Compromise Agreement between the Deudors and Tuason, wherein Tuason acknowledged the Deudors’ vendees and agreed to sell them lots at set prices.
The trial court dismissed the complaint. It ruled that the cause of action, rooted in the Compromise Agreement, was extinguished because the Supreme Court had declared that agreement rescinded in prior cases (Deudor vs. J. M. Tuason & Co., Inc. and J. M. Tuason & Co., Inc. vs. Sanvictores). The rescission was due to the Deudors’ failure to deliver peaceful possession of the land to Tuason.
ISSUE
Whether the complaint states a cause of action against J. M. Tuason & Co., Inc. despite the rescission of the underlying Compromise Agreement.
RULING
The Supreme Court affirmed the dismissal, holding the complaint stated no cause of action. The legal logic is straightforward: a cause of action must be based on a valid, existing obligation. The plaintiffs’ entire claim was premised on the rights and obligations created by the 1953 Compromise Agreement. Since that agreement had been judicially rescinded, it ceased to have any legal force or effect. Consequently, any derivative right the plaintiffs claimed under it—specifically, the right to compel Tuason to sell them the lot—was extinguished.
The Court distinguished this case from Evangelista vs. Deudor, where a cause of action was found. In Evangelista, the action was filed before the Compromise Agreement was rescinded, and the plaintiff was an immediate vendee of Deudor listed in the agreement. Here, the plaintiffs were not immediate vendees, were not listed in the agreement, and filed their action years after its rescission. Therefore, they could not anchor their claim on an already-nullified contract. With the foundational agreement voided, no enforceable obligation from Tuason to the plaintiffs remained.