G.R. No. L-5529; May 15, 1953
FORTUNATA RAMENTO, ET AL., plaintiffs-appellants, vs. GUADALUPE COSUANGCO, defendant-appellee.

FACTS

On May 10, 1944, spouses Adriano Mendoza and Fortunata Ramento sold eight parcels of registered land in Guimba, Nueva Ecija, to Guadalupe Cosuangco for P75,862. On that day, Cosuangco paid P30,000, promising to pay the balance later. She subsequently made two payments totaling P28,000. On July 9, 1944, Cosuangco signed a statement (Exhibit A/6) acknowledging total payments of P58,000 and a remaining balance of P18,000, which she promised to pay upon delivery of the titles held by Attorney Salva. The titles were later delivered, and transfer certificates were issued in Cosuangco’s name. In August 1948, Fortunata Ramento and her children (heirs of the deceased Adriano Mendoza) sued to rescind the sale, alleging non-payment of the P18,000 balance. Cosuangco claimed full payment, presenting a document (Exhibit 2) dated September 14, 1944, signed by Fortunata Ramento, acknowledging receipt of P14,000 and stating that the total price of P75,862 had been fully satisfied. Cosuangco also presented a promissory note (Exhibit 5) dated July 1, 1945, signed by Fortunata for a P150 loan. Fortunata testified that she was deceived into signing Exhibit 2 and that Exhibit 5 was merely a receipt for a partial payment on the balance. The trial court credited the documentary evidence, found full payment, and ordered Fortunata to repay the P150 loan with interest. Plaintiffs appealed.

ISSUE

Whether the trial court erred in finding that the full purchase price had been paid, thereby precluding rescission of the sale.

RULING

The Supreme Court affirmed the trial court’s decision. The Court found no reason to reverse the trial judge’s appraisal of the conflicting evidence. The key document was Exhibit 5, the promissory note for a P150 loan dated July 1, 1945, which was concededly signed by Fortunata. The Court found Fortunata’s claim that she signed it in ignorance not credible, especially given her prior allegation of being deceived by Exhibit 2. If the P150 were a payment on the purchase price, she would have credited it in her complaint. The fact that she borrowed money from Cosuangco in July 1945 supported Cosuangco’s claim that the purchase price had been fully satisfied earlier, as per Exhibit 2. Furthermore, the delivery of the titles to Cosuangco, as required by Exhibit A for payment of the P18,000 balance, logically indicated that the balance had been paid. The Court declined to entertain the appellants’ new legal argument—that Fortunata lacked authority to receive the final payment on behalf of her husband’s heirs—as it was not raised in the lower court pleadings. The appealed decision was affirmed, with costs against appellants.