Catholic Church sells 32sqm lot in Naga City (CASE DIGEST: RCC v. Pante; G.R. No. 174118)

CASE DIGEST: ROMAN CATHOLIC CHURCH V. PANTE (G.R. No. 174118, April 11, 2012)

FACTS: The Roman Catholic Church sold a 32-square meter lot located in Naga City to Regino Pante, and sold a bigger lot to Spouses Nestor and Fidela Rubi which included the smaller lot. When the Rubi spouses asserted ownership over the lot, and constructed a fence over the lot blocking the Pante's access from their family home, a complaint was filed to annul the sale between the Church and the Spouses Rubi insofar as the 32 square meter lot is concerned. The Church filed an answer with a counterclaim seeking annulment of the sale to Pante on the ground that its consent was obtained by fraud and in bad faith since he misrepresented that he had been an actual occupant of the lot sold to him when in fact, he was not. It contended that it is the policy of the Church to sell only to actual occupants; hence, the contract is voidable. The Rubi spouses were not likewise residents of the lot sold to them.
ISSUE: Does the Church's policy of selling only to actual occupants make the contract voidable?

The contention is not correct; the contract does not become voidable simply because of the policy of the church. The actual occupancy or residency of a buyer over the land does not appear to be a necessary qualification that the Church requires before it could sell its land. Had this been indeed its policy, then neither of the parties would qualify as buyers of the 32-square meter lot, as none of them actually occupied or resided on the lot.

Before the sale, there was a series of conferences with the occupants of the lots. The buyer was not an occupant of the lot, yet he was allowed to purchase and it was approved, hence, there could have been no deliberate, willful or fraudulent act committed.

In the absence of any vitiation of consent, the contract between the Church and Pante stands valid and existing. Any delay by Pante in paying the full price could not nullify the contract, since (as correctly observed by the CA) it was a contract of sale. By its terms, the contract did not provide a stipulation that the Church retained ownership until full payment of the price. The right to repurchase given to the Church in case Pante fails to pay within the grace period provided would have been unnecessary had ownership not already passed to Pante.