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MANUEL C. BUNGCAYAO v. FORT ILOCANDIA PROPERTY HOLDINGS

FACTS:

Manuel C. Bungcayao, Sr. claimed to be one of the entrepreneurs who introduced improvements on the foreshore area of Calayab Beach. Other entrepreneurs formed the D'Sierto Beach Resort Owner's Association, Inc. (D'Sierto). In 1980, parcels of land in Barrio Balacad were transferred to the Philippine Tourism Authority (PTA), and Fort Ilocandia Resort Hotel was built on the area. Petitioner and other D'Sierto members applied for a foreshore lease, but their applications were denied by the Department of Environment and Natural Resources (DENR). A letter inviting the D'Sierto members to a luncheon meeting was sent by Fort Ilocandia Property Holdings and Development Corporation (respondent). At the meeting, a financial settlement was offered to the D'Sierto members in exchange for vacating the area identified as respondent's property. Petitioner's son attended the meeting and under undue pressure, accepted the payment and signed a deed of assignment in favor of respondent. Petitioner filed an action for the nullity of the contract, claiming that his son had no authority to represent him. The trial court confirmed the agreement to cancel the deed but petitioner maintained his claim for damages. The trial court, through summary judgment, dismissed petitioner's claim for damages, granted respondent's counterclaim for recovery of possession of the occupied property, and ordered petitioner to vacate the premises. The Court of Appeals affirmed the trial court's decision.

ISSUES:

  1. Whether the alleged pressure exerted by Atty. Marcos on petitioner's son vitiated his consent to enter into a Deed of Assignment, Release, Waiver and Quitclaim.

  2. Whether the property occupied by petitioner is within the titled property of respondent.

  3. Whether petitioner's claim for damages has legal basis.

RULING:

  1. The alleged pressure exerted by Atty. Marcos on petitioner's son did not vitiate his consent to enter into a Deed of Assignment, Release, Waiver and Quitclaim.

  2. The property occupied by petitioner is within the titled property of respondent.

  3. Petitioner's claim for damages has no legal basis.

PRINCIPLES:

  • Consent to a contract is not vitiated by pressure unless it amounts to force, violence or intimidation that would disable a party from exercising free will.

  • The location of a property, as indicated in a title, is a strong presumption of ownership.

  • A claim for damages should have a legal basis.