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Solid Homes, Inc. v. Evelina Laserna and Gloria Cajipe

In the case of Solid Homes, Inc. v. Evelina Laserna and Gloria Cajipe, the Supreme Court upheld the decisions of lower courts regarding the execution of a Deed of Sale and Transfer Certificate of Title despite the respondents' incomplete payment. The Court affirmed the validity of 'memorandum decisions' by adjudicatory bodies and clarified that incomplete payment does not invalidate a cause of action for specific performance under real estate laws. This case highlights the protective provisions of Philippine laws for buyers against wrongful rescission by sellers.

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7 views2 pages

Solid Homes, Inc. v. Evelina Laserna and Gloria Cajipe

In the case of Solid Homes, Inc. v. Evelina Laserna and Gloria Cajipe, the Supreme Court upheld the decisions of lower courts regarding the execution of a Deed of Sale and Transfer Certificate of Title despite the respondents' incomplete payment. The Court affirmed the validity of 'memorandum decisions' by adjudicatory bodies and clarified that incomplete payment does not invalidate a cause of action for specific performance under real estate laws. This case highlights the protective provisions of Philippine laws for buyers against wrongful rescission by sellers.

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via rose colonia
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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G.R. No. 166051.

April 08, 2008 (Case Brief / Digest)

### Title:
Solid Homes, Inc. v. Evelina Laserna and Gloria Cajipe

### Facts:
The detailed sequence of events began on 1 April 1977 when Evelina Laserna and Gloria
Cajipe, represented by Proceso F. Cruz, entered into a Contract to Sell with Solid Homes, Inc.
(petitioner) for a lot in Quezon City. After making a down payment and several installments,
the respondents demanded the execution and delivery of the Deed of Sale and the Transfer
Certificate of Title (TCT) upon their alleged final payment. The petitioner’s refusal led the
respondents to lodge a complaint with the Housing and Land Use Regulatory Board (HLURB)
on 28 June 1990. The HLURB Arbiter directed SHI to execute and deliver the Deed of Sale
and TCT once the purchase price was fully settled, a decision modified by the HLURB Board
of Commissioners to include the precise remaining balance. Solid Homes, Inc appealed to the
Office of the President, which upheld the HLURB’s decision. Unconvinced, SHI moved to the
Court of Appeals via Petition for Review, alleging errors in adherence to procedural
standards by the lower adjudicatory bodies, but the appellate court dismissed this petition.
Following a denied Motion for Reconsideration, the petitioner sought recourse from the
Supreme Court, raising issues on procedural improprieties and the respondents’ cause of
action due to incomplete payment.

### Issues:
1. Whether the Court of Appeals erred in affirming the Office of the President’s decision,
which adopted the findings and conclusions of the HLURB Board of Commissioners.
2. Whether the Court of Appeals erred by not finding that the respondents’ complaint to the
HLURB lacked cause of action due to incomplete payment.

### Court’s Decision:


The Supreme Court denied the petition for review, affirming the decisions of the lower courts
and adjudicatory bodies. It highlighted the validity of “memorandum decisions,” acceptable
when they provide direct access to adopted findings and ensure an informed appeal process.
It was determined that the Decision of the Office of the President, adopting the HLURB Board
of Commissioners’ findings, complied with constitutional and administrative due process
requirements. Further, the Court noted that the respondent’s failure to fully pay the purchase
price does not preclude them from filing a complaint with the HLURB due to wrongful
rescission by petitioner and under the protective provisions of PD 957 and RA 6552.

### Doctrine:

© 2024 - batas.org | 1
G.R. No. 166051. April 08, 2008 (Case Brief / Digest)

This case reiterates the doctrine on the validity of “memorandum decisions” by superior
adjudicatory bodies, provided they attach and directly refer to the findings of fact and
conclusions of law from the decisions of lower courts or tribunals. It also clarifies the
applicability of constitutional requirements on decision-writing to administrative bodies,
noting that such requirements are not mandatory for administrative decisions. Furthermore,
the case discusses the conditions under which incomplete payment of purchase price does
not invalidate a cause of action for specific performance under real estate laws.

### Class Notes:


– **Memorandum Decisions**: Valid if they include direct access to the findings of fact and
conclusions of law adopted by reference, intended for judicial efficiency.
– **Application of Constitutional Provisions**: Section 14, Article VIII of the 1987 Philippine
Constitution, mandating clear expression of facts and law in decisions, does not directly apply
to administrative proceedings.
– **Rights under Administrative Proceedings**: Adherence to procedural due process is
satisfied so long as parties are afforded the opportunity to be heard and the decision is based
on substantial evidence with reasons for the decision made known.
– **Cause of Action in Payment Disputes**: Under PD 957 and RA 6552, the failure to fully
pay the purchase price under a Contract to Sell does not necessarily preclude the filing of a
complaint against wrongful rescission by the seller.

### Historical Background:


The procession through various administrative and judicial avenues in this case provides
insight into the procedural mechanisms available to parties in real estate disputes in the
Philippines. It underscores the protective legislative framework established by PD 957 (The
Subdivision and Condominium Buyers’ Protective Decree) and RA 6552 (Realty Installment
Buyer Protection Act), reflecting the Philippine government’s intention to safeguard buyers
against premature and wrongful rescission by developers or sellers.

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