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ROMEL P. ALMEDA v. LEONOR A. CARIÑO

FACTS:

Ponciano L. Almeda and Avelino G. Cariño entered into a sale agreement on April 30, 1980, for several properties located in Biñan, Laguna. The purchase price was to be paid in installments, with interest, and certain conditions were stipulated in the agreement. On April 3, 1982, an amendment to the agreements was executed, extending the deadline for producing titles to untitled properties and making other provisions.

Almeda requested the execution of a Deed of Absolute Sale for the titled properties before they were fully paid, and Cariño granted the request. Thus, on May 3, 1982, the Deed of Absolute Sale was executed.

However, despite the execution of the Deed of Absolute Sale, Almeda and Almeda, Inc., to whom the properties were transferred, failed to pay the balance. Cariño then demanded payment, but Almeda and Almeda, Inc. did not comply.

As a result, Cariño filed a complaint, and the Regional Trial Court (RTC) of Biñan ruled in his favor. The RTC ordered Almeda and Almeda, Inc. to pay the balance, along with interest, nominal damages, and attorney's fees.

In response, Almeda and Almeda, Inc. appealed to the Court of Appeals, challenging the awards of nominal damages and attorney's fees, as well as the imposition of a 12% interest rate.

ISSUES:

  1. Whether the lower court erred in awarding nominal damages and attorney's fees in favor of Cariño.

  2. Whether the lower court erred in imposing a 12% annual interest on the judgment debt from the time of demand until fully paid.

RULING:

  1. The Court of Appeals affirmed the lower court's decision. Therefore, the award of nominal damages and attorney's fees in favor of Cariño is upheld.

  2. The Court of Appeals did not mention anything regarding the lower court's imposition of a 12% annual interest. Therefore, the ruling on this issue is not provided in the decision.

PRINCIPLES:

  • The buyer or vendee must pay the balance of the purchase price, including interest charges, to the vendor or seller. Failure to do so can result in legal consequences, such as payment of damages and attorney's fees (not specified in this case).

  • The interest rate on the judgment debt is not provided in the decision.