### Facts
Benjamin Castillo was the registered owner of a large parcel of land in Laurel, Batangas, Philippines. Olivarez Realty Corporation, represented by Dr. Pablo R. Olivarez, entered into a contract of conditional sale with Castillo, agreeing to buy the land for PHP 19,080,490.00, with a down payment and the balance payable in monthly installments after a court decision nullifying the Philippine Tourism Authority’s claim to the same land. The agreement also stipulated obligations about legal actions against the Philippine Tourism Authority, disturbance compensation for tenants, and land clearance which were not fulfilled by Olivarez Realty.
On September 2, 2004, Castillo filed a complaint against Olivarez Realty Corporation and Dr. Olivarez, alleging substantial breach of contract, and the case underwent several legal motions, including a request for admission, motions for summary judgment by Castillo, oppositions and supplemental arguments from Olivarez Realty, ultimately leading to a trial court decision in favor of Castillo. The Court of Appeals affirmed this decision, which Olivarez Realty Corporation then appealed to the Supreme Court.
### Issues
1. Whether the trial court erred in rendering a summary judgment.
2. Whether the proper docket fees were paid in the case.
### Court’s Decision
The Supreme Court denied the appeal, affirming the decisions of the lower courts with modifications. It concluded:
1. The trial court correctly rendered a summary judgment as there were no genuine issues of material fact. Olivarez Realty’s failures—including not paying the purchase price fully, not filing actions against the Philippine Tourism Authority as agreed, and not clearing the property of tenants—were undisputed and actionable.
2. The Supreme Court ruled that Castillo paid the correct docket fees since the nature of his action—a call for the rescission (in practice, cancellation) of a contract to sell—was correctly considered incapable of pecuniary estimation.
### Doctrine
The Supreme Court reiterated that a summary judgment is appropriate when there is no genuine issue as to any material fact and that a trial can be dispensed with. Furthermore, it clarified distinctions between contracts of conditional sale and contracts to sell, emphasizing that non-fulfillment of payment obligations in contracts to sell does not constitute a breach under Article 1191 of the Civil Code but instead prevents the obligation to convey title from acquiring obligatoriness.
### Class Notes
– **Summary Judgment**: Appropriate when there is no genuine issue of material fact.
– **Contracts to Sell vs. Conditional Sale**: Distinguished by whether the transfer of title is automatic upon full payment.
– **Doctrine**: Non-payment in a contract to sell does not constitute a breach under Article 1191 but prevents the contract from becoming obligatory.
– **Docket Fees for Actions Incapable of Pecuniary Estimation**: The determination of the nature of the action dictates the computation of docket fees.
### Historical Background
This case elucidates the complexities surrounding real estate transactions in the Philippines, specifically issues involving conditional sales, genuine issues for trial, and the procedural aspects of litigation such as the use of summary judgments and the calculation of docket fees. The ruling showcases the judicial system’s handling of disputes stemming from failures to fulfill contractual obligations in property sales, reflecting on the broader context of property rights and contract law in the country.
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