Persons Stare Decisis 15 Aug 2018 Alrick and Rikki
CASE NAME: UCPB v. spouses Walter and Lily Uy, G.R. No. 204039 PONENTE: MARTIRES, J. Case Date: January 10, 2018 Case Summary: Respondents Walter and Lily Uy filed a complaint for sum of money and damages against PPGI and its successor-in-interest UCPB, claiming that despite paying in full for a unit in Kiener Hills, PPGI failed to complete the construction of their unit. The case reached the CA which in its decision, applied UCPB v. O’Halloran under the principle of stare decisis. SC ruled that the CA erred in its reliance on the decision in UCPB v. O’Halloran as a binding precedent since it was not issued by the SC. Rule of Law/Doctrine: Only decisions issued by the SC become part of the legal system. At the most, decisions of lower courts only have a persuasive effect.
Detailed Facts: - Prime Town Property Group, Inc. (PPGI) and E. Ganzon, Inc. were the joint developers of the Kiener Hills Mactan Condominium Project. - In 1997, spouses Walter and Lily Uy (respondents) entered into a Contract to Sell with PPGI for a unit in Kiener Hills amounting to P1,151,718.75 payable according to the following terms: (a) P100,000.00 as down payment; and (b) the balance paid in 40 monthly installments at P26,297.97 from 16 January 1997 to 16 April 2000. - On 23 April 1998, as partial payment of PPGI’s loan to petitioner United Coconut Planters Bank (UCPB), PPGI entered in to an agreement with UCPB, which had the effect of, among others, transferring the right to collect receivables from the buyers of units in Kiener Hills to UCPB. - On 17 April 2006, the respondents filed with the HLURB Regional Office, a complaint for sum of money and damages against PPGI and UCPB, claiming that despite their full payment of the purchase price, PPGI failed to complete the construction of their unit in Kiener Hills. - On 29 November 2006, HLURB regional office found that respondents were entitled to a refund but held that UCPB cannot be solidarily liable with PPGI as only the accounts receivable were conveyed to them and not the entire condominium project. - The HLURB regional office suspended the proceedings as to PPGI on account of its being in corporate rehabilitation. Respondents were then directed to the Rehabilitation Receiver to file their claim. - Unsatisfied, respondents appealed before the HLURB-Board of Commissioners who then reversed the regional office’s decision, finding UCPB, as PPGI’s successor-in-interest, to be solidarily liable with PPGI, and was ordered to refund to the complainant the total amount with interest at the legal rate of 6% per annum until fully paid. - UCPB appealed before the OP which affirmed the decision of the HLURB board. - UCPB then appealed before the CA which affirmed with modification the OP’s decision. It held that the respondents are entitled to a full refund while also ruling that the UCPB is not solidarily liable with PPGI, hence limiting UCPB’s liability to the amount respondents have paid after UCPB assumed the right to collect the receivables. - Citing similarities in facts and issues with UCPB v. O'Halloran, a case previously decided by the CA with finality, the CA ruled that the assignment of the receivables did not make UCPB the developer of Kiener Hills, and as such, UCPB cannot be deemed as the debtor with respect to the construction, development, and delivery of the subject condominium units. - UCPB moved for reconsideration but was denied. - UCPB appealed to the SC raising that the CA erred in applying UCPB v. O’Halloran and in finding them liable for the amount which they did not receive. Issue: W/N the decision of the CA in UCPB v. O’Halloran is applicable to the instant case under the principle of stare decisis? Holding: - No. The decision in UCPB v. O’Halloran is not a binding precedent since it was not issued by the SC. - In De Mesa v. Pepsi-Cola Products Phils. Inc, the SC explained the doctrine of stare decisis: o “... it requires our courts to follow a rule already established in a final decision of the Supreme Court. That decision becomes a judicial precedent to be followed in subsequent cases by all courts in the land. The doctrine of stare decisis is based on the principle that once a question of law has been examined and decided, it should be deemed settled and closed to further argument…” - The doctrine of stare decisis becomes operative only when judicial precedents are set by pronouncements of the SC to the exclusion of lower courts - Regardless whether the decisions of the lower courts are logically or legally sound, only decisions issued by the SC become part of the legal system. At the most, decisions of lower courts only have a persuasive effect. Ruling: SC AFFIRMED with MODIFICATION the decision of the CA Relevant Provisions NCC Art 8. Judicial decisions applying or interpreting the laws or the Constitution shall form a part of the legal system of the Philippines.
Third Division January 10, 2018 G.R. No. 204039 United Coconut Planters Bank, Petitioner Spouses Walter Uy and Lily Uy, Respondents Decision Martires, J.
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