Araneta v. Philippine Sugar Estate Development Co.

G.R. No. L-22558, 31 May 1967

FACTS:

J.M. Tuason & Co., Inc. through Gregorio Araneta, Inc. sold a portion of their land to Philippine Sugar Estates Development with a condition that the buyer will build a church in the said land while the seller will construct a street within the property. The buyer had already finished building the church while the seller had failed to do the construction of the street in Northeast side because a certain person was occupying its middle portion and refused to vacate.

Now the buyer filed a case in court contending that the seller must evict the person occupying the property and finish the construction. The seller now contends that the case was premature because it is without definite period. The lower court then gave a two year period to seller to evict the squatter and to construct the street.

ISSUE:

Whether or not the parties agreed that the petitioner should have reasonable time to perform its part of the bargain

RULING:

If the contract so provided, then there was a period fixed, a “reasonable time;” and all that the court should have done was to determine if that reasonable time had already elapsed when suit was filed if it had passed, then the court should declare that petitioner had breached the contract, as averred in the complaint, and fix the resulting damages. On the other hand, if the reasonable time had not yet elapsed, the court perforce was bound to dismiss the action for being premature.

Article 1197 of the Civil Code involves a two-step process. The Court must first determine that “the obligation does not fix a period but from the nature and the circumstances it can be inferred that a period was intended”. The Court must then proceed to the second step, and decide what period was “probably contemplated by the parties” So the Court cannot fix a period merely because in its opinion it is or should be reasonable, but must set the time that the parties are shown to have intended.

In this connection, it is to be borne in mind that the contract shows that the parties were fully aware that the land described therein was occupied by squatters. As the parties must have known that they could not take the law into their own hands, but must resort to legal processes in evicting the squatters, they must have realized that the duration of the suits to be brought would not be under their control nor could the same be determined in advance. The conclusion is thus forced that the parties must have intended to defer the performance of the obligations under the contract until the squatters were duly evicted, as contended by the petitioner Gregorio Araneta, Inc.

* Case digest by Aileen B. Buenafe, LLB-1, Andres Bonifacio Law School, SY 2017-2018

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