CASE DIGEST: GUZMAN, BOCALING & CO V. BONNEVIE

 


GUZMAN, BOCALING & CO., petitioner, vs. RAOUL S.V. BONNEVIE, respondent
G.R. No. 86150                  |              March 2, 1992

 

FACTS:

Africa Valdez de Reynoso, the administratrix of the Intestate Estate of Jose L. Reynoso, leased a 600 sq. m. of land with 2 building constructed thereon, to Raoul S. Bonnevie and Christopher Bonnevie for a period of 1 year beginning Aug. 8, 1976 at a monthly rental of P4,000.00.

The Contract of lease contained the following stipulation:

“In case the LESSOR desires or decides to sell the leased property, the LESSEES shall be given a first priority to purchase the same, all things and considerations being equal.”

On November 3, 1976, Reynoso notified private respondents that she was selling the leased premises and was giving them 30 days to exercise their right of first priority to purchase the subject property. She said that in the event that they did not exercise the said right, she would expect them to vacate the property not later than March 1977. In view of their failure to exercise their right of first priority, Reynoso sent another letter notifying the respondents that she has already sold the property.

Private respondents denied receiving her letter dated Nov. 3, 1976 and that they had advised her agent to inform them officially should she decide to sell the property so negotiations could be initiated; and that they were “constrained to refuse (her) request for the termination of the lease.”

On March 7, 1977, the leased premises were formally sold to petitioner Guzman, Bocaling & Co. The Contract of Sale provided for immediate payment of P137,500.00 on the purchase price, the balance of P262,500.00 to be paid only when the premises were vacated.

On April 12, 1977, Reynoso wrote a letter to the private respondents demanding that they vacate the premises within 15 days for their failure to pay the rentals for four months. When they refused, Reynoso filed a complaint for ejectment against them.

While the ejectment case was pending, private respondents filed an action for annulment of the sale between Reynoso and herein petitioner Guzman, Bocaling & Co. They also asked that Reynoso be required to sell the property to them under the same terms and conditions agreed upon in the Contract of Sale in favor of the petitioner.

ISSUE:

Was there a violation of respondent’s right of first priority

RULING:

Even if the letter had indeed been sent to and received by the private respondents and they did not exercise their right of first priority, Reynoso would still be guilty of violating Paragraph 20 of the Contract of Lease which specifically stated that the private respondents could exercise the right of first priority, “all things and conditions being equal.” The Court reads this to mean that there should be identity of the terms and conditions to be offered to the Bonnevies and all other prospective buyers, with the Bonnevies to enjoy the right of first priority.

The selling price quoted to the Bonnevies was P600,000.00, to be fully paid in cash less only the mortgage lien of P100,000.00. On the other hand, the selling price offered to and accepted by the petitioner was only P400,000.00, and only P137,500.00 was paid in cash while the balance of P272,500.00 was to be paid “when the property (was) cleared of tenants or occupants.”

The fact that the Bonnevies had financial problems at that time was no justification for denying them the first option to buy the subject property. Even if the Bonnevies could not buy it at the price quoted, Reynoso could not sell it to another for a lower price and under more favorable terms and conditions. Only if the Bonnevies failed to exercise their right of first priority could Reynoso lawfully sell the subject property to others, and at that only under the same terms and conditions offered to the Bonnevies.

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