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CHARLES CU-UNJIENG v. CA

FACTS:

Charles Cu-Unjieng filed a complaint against Union Bank of the Philippines (UBP) and Register of Deeds of Bulacan alleging a perfected contract of sale between him and UBP for a parcel of agricultural land owned by UBP. UBP rejected the petitioner's offer to buy the land for a lesser amount, stating that the land was covered by the Comprehensive Agrarian Reform Law and could only be disposed of through specific procedures. The Regional Trial Court dismissed the petitioner's complaint for lack of a sufficient cause of action but ordered UBP to reimburse the petitioner the amount of P103,915.27 as earnest money with interest. The petitioner filed an appeal with the Court of Appeals (CA), but it was dismissed for non-payment of docket fees and his motion for reconsideration was also denied. Charles Cu-Unjieng now seeks the reversal of these issuances through a petition for review on certiorari.

ISSUES:

  1. Whether there was a perfected contract of sale between the petitioner and respondent Union Bank of the Philippines (UBP) with regard to the subject property.

  2. Whether the trial court erred in dismissing the petitioner's complaint for lack of sufficient cause of action.

RULING:

  1. The Supreme Court held that there was no perfected contract of sale between the petitioner and UBP. The Court found that UBP rejected the petitioner's offer to purchase the subject property and refunded the petitioner's earnest money. Thus, there was no meeting of minds between the parties, which is an essential element of a contract of sale.

  2. The Supreme Court affirmed the trial court's dismissal of the petitioner's complaint for lack of sufficient cause of action. The Court found that there was no legal basis for the petitioner to demand specific performance from UBP since there was no perfected contract of sale. The Court also upheld the trial court's order for UBP to reimburse the petitioner's earnest money.

PRINCIPLES:

  • A contract of sale requires a meeting of minds between the parties as to the object of the sale and the price. Without a meeting of minds, there is no perfected contract of sale.

  • A cause of action must be based on a right that is recognized and protected by law. Without a sufficient cause of action, a complaint may be dismissed for lack of legal basis.

  • Earnest money must be returned when there is no perfected contract of sale.