Abad v. Goldloop Properties,Inc. G.R. No.

168108 APRIL 13, 2007

FACTS: Petitioner Abad et. al were owners of 13parcels of titled agriculturalland

situated in Malabon Estate,Tanza Cavite. Respondent Goldloop Properties Inc entered
into a contract of Conditional Sale with petitioners for the entire land and agreed for an
earnest money of 1M, PHP6,765,660.00 shall be paid on Auguat 19,1997 and the
remaining balancebe paid on December 31,2017. They agreed that in the event
respondent fails to fulfill it obligation, the earnest money shall be forefeied to the
petitioners and the first payment shall be returned.

Respondent thru its President informed that the negotiations with the banks had
failed due to economic downturn and consequently, the transaction would not be
consummated, hence,asked for the return of the first payment. Respondent filed a
complaint for collection which the RTC ruled in its favor declaring that the contract shall
be given effect. Petitioners moved for reconsideration but was denied. On appeal, CA
affirmed in toto the ruling of the RTC and declared that petitioners obligation to return
the first payment was an unconditional one. Petitioners moved for reconsideration which
the partly graned and declared petitioners only joint and not in solidum. Hence, this
petition.

ISSUE: Whether the obligation of petitioners to return the first payment of

P6,765,660.00 is an unconditional obligation or not pursuant to the contract

RULING: Yes. The Supreme Court ruled that contract should be contrued in it literal
meaning,hence, first payment must be returned pursuant to the contract. The cardinal
rule in the interpretation of contracts is embodied in the first paragraph of Article 1370 of
the Civil Code: [i]f the terms of a contract are clear and leave no doubt upon the
intention of the contracting parties, the literal meaning of its stipulations shall control.
This provision is akin to the plain meaning rule applied by Pennsylvania courts, which
assumes that the intent of the parties to an instrument is embodied in the writing itself,
and when the words are clear and unambiguous the intent is to be discovered only from
the express language of the agreement

In our jurisdiction, the rule is thoroughly discussed in Bautista v. Court of Appeals,

322 SCRA 365 (2000): The rule is that where the language of a contract is plain and
unambiguous, its meaning should be determined without reference to extrinsic facts or
aids. The intention of the parties must be gathered from that language, and from that
language alone. Stated differently, where the language of a written contract is clear and
unambiguous, the contract must be taken to mean that which, on its face, it purports to
mean, unless some good reason can be assigned to show that the words should be
understood in a different sense. Courts cannot make for the parties better or more
equitable agreements than they themselves have been satisfied to make, or rewrite
contracts because they operate harshly or inequitably as to one of the parties, or alter
them for the benefit of one party and to the detriment of the other, or by construction,
relieve one of the parties from the terms which he voluntarily consented to, or impose
on him those which he did not
Association of Small Landowners vs. Secretary of DAR, G.R. No. 78742, July
14,1989.

FACTS: These are four consolidated cases questioning the constitutionality of the
Comprehensive Agrarian Reform Act (R.A. No. 6657 and related laws i.e., Agrarian
Land Reform Code or R.A. No. 3844).

Article XIII of the Constitution on Social Justice and Human Rights includes a call for the
adoption by the State of an agrarian reform program. The State shall, by law, undertake
an agrarian reform program founded on the right of farmers and regular farmworkers,
who are landless, to own directly or collectively the lands they till or, in the case of other
farmworkers, to receive a just share of the fruits thereof. RA 3844 was enacted in 1963.
P.D. No. 27 was promulgated in 1972 to provide for the compulsory acquisition of
private lands for distribution among tenant-farmers and to specify maximum retention
limits for landowners. In 1987, President Corazon Aquino issued E.O. No. 228,
declaring full land ownership in favor of the beneficiaries of PD 27 and providing for the
valuation of still unvalued lands covered by the decree as well as the manner of their
payment. In 1987, P.P. No. 131, instituting a comprehensive agrarian reform program
(CARP) was enacted; later, E.O. No. 229, providing the mechanics for its (PP131s)
implementation, was also enacted. Afterwhich is the enactment of R.A. No. 6657,
Comprehensive Agrarian Reform Law in 1988. This law, while considerably changing
the earlier mentioned enactments, nevertheless gives them suppletory effect insofar as
they are not inconsistent with its provisions.

In G.R. No. 78742: (Association of Small Landowners vs Secretary) the Association of

Small Landowners in the Philippines, Inc. sought exception from the land distribution
scheme provided for in R.A. 6657. The Association is comprised of landowners of
ricelands and cornlands whose landholdings do not exceed 7 hectares. They invoke
that since their landholdings are less than 7 hectares, they should not be forced to
distribute their land to their tenants under R.A. 6657 for they themselves have shown
willingness to till their own land. In short, they want to be exempted from agrarian reform
program because they claim to belong to a different class.

While in G.R. No. 79777: (Manaay vs Juico) Nicolas Manaay questioned the validity of
the agrarian reform laws (PD 27, EO 228, and 229) on the ground that these laws
already valuated their lands for the agrarian reform program and that the specific
amount must be determined by the Department of Agrarian Reform (DAR). Manaay
averred that this violated the principle in eminent domain which provides that only courts
can determine just compensation. This, for Manaay, also violated due process for under
the constitution, no property shall be taken for public use without just compensation.

Manaay also questioned the provision which states that landowners may be paid for
their land in bonds and not necessarily in cash. Manaay averred that just compensation
has always been in the form of money and not in bonds. Hence, this petition.
ISSUES:

1. Whether or not there was a violation of the equal protection clause.

2. Whether or not there is a violation of due process.
3. Whether or not just compensation, under the agrarian reform program, must be in
terms of cash.

HELD:

1. No. The Association had not shown any proof that they belong to a different class
exempt from the agrarian reform program. Under the law, classification has been
defined as the grouping of persons or things similar to each other in certain particulars
and different from each other in these same particulars. To be valid, it must conform to
the following requirements:

(1) it must be based on substantial distinctions;

(2) it must be germane to the purposes of the law;

(3) it must not be limited to existing conditions only; and

(4) it must apply equally to all the members of the class.

Equal protection simply means that all persons or things similarly situated must be
treated alike both as to the rights conferred and the liabilities imposed. The Association
have not shown that they belong to a different class and entitled to a different treatment.
The argument that not only landowners but also owners of other properties must be
made to share the burden of implementing land reform must be rejected. There is a
substantial distinction between these two classes of owners that is clearly visible except
to those who will not see. There is no need to elaborate on this matter. In any event, the
Congress is allowed a wide leeway in providing for a valid classification. Its decision is
accorded recognition and respect by the courts of justice except only where its
discretion is abused to the detriment of the Bill of Rights. In the contrary, it appears that
Congress is right in classifying small landowners as part of the agrarian reform program.

2. No. It is true that the determination of just compensation is a power lodged in the
courts. However, there is no law which prohibits administrative bodies like the DAR from
determining just compensation. In fact, just compensation can be that amount agreed
upon by the landowner and the government even without judicial intervention so long
as both parties agree. The DAR can determine just compensation through appraisers
and if the landowner agrees, then judicial intervention is not needed. What is
contemplated by law however is that, the just compensation determined by an
administrative body is merely preliminary. If the landowner does not agree with the
finding of just compensation by an administrative body, then it can go to court and the
determination of the latter shall be the final determination. This is even so provided by
RA 6657:
Section 16 (f): Any party who disagrees with the decision may bring the matter to the
court of proper jurisdiction for final determination of just compensation.

3. No. Money as [sole] payment for just compensation is merely a concept in traditional
exercise of eminent domain. The agrarian reform program is a revolutionary exercise of
eminent domain. The program will require billions of pesos in funds if all compensation
have to be made in cash if everything is in cash, then the government will not have
sufficient money hence, bonds, and other securities, i.e., shares of stocks, may be used
for just compensation.

Arceta vs. Mangrobang,GR 152895, 15 June 2004

Facts: On 16 September 1998, petitioner Ofelia Arceta issued a check to Oscar Castro
payable to cash for the amount of Php 740k even with full knowledge that the account
has no sufficient fund for the said amount. The check was subsequently dishonoured by
the bank.

The City Prosecutor of Metro Manila charged Arceta of violating BP Blg 22 (Bouncing
Checks Law). She did not moved for the charge to be dismissed and pleaded not guilty
However, she manifested that her arraignment should be without prejudice to the
present petition or to any other actions she would take to suspend proceedings in the
trial court. Hence, this petition for certiorari, prohibition and mandamus assailing the
constitutionality of BP Blg 22.

Issue: Whether or not the constitutionality of BP Blg 22 is the lis mota of the case?

RULING: The Supreme Court dismissed the petition. Every law has in its favour the
presumption of constitutionality. To justify its nullification there must be a clear and
unequivocal breach of the constitution and not one that is speculative, doubtful or
argumentative. Petitioner failed to show that BP Blg 22 by itself or by implementation
transgressed a provision of the Constitution.

Seeking judicial review at the earliest opportunity does not mean immediately elevating
the matter to this Court. Earliest opportunity means that the question of
unconstitutionality of the act in question should have been immediately raised in the
proceedings in the court below. Thus, the petitioners should have moved to quash the
separate indictments or moved to dismiss the cases in the proceedings in the trial
courts on the ground of unconstitutionality of B.P. Blg. 22. But the records show that
petitioners failed to initiate such moves in the proceedings below. Needless to
emphasize, this Court could not entertain questions on the invalidity of a statute where
that issue was not specifically raised, insisted upon, and adequately argued. Taking into
account the early stage of the trial proceedings below, the instant petitions are patently
premature.