**Dr. Restituto C. Buenviaje vs. Spouses Jovito R. and Lydia B. Salonga, et al.**
### Facts:
Dr. Restituto C. Buenviaje entered into a contractual relationship with Jebson Holdings Corporation (Jebson) for the purchase of a residential unit in Brentwoods Tagaytay Villas. The property belonged to Spouses Salonga who had entered into a Joint Venture Agreement (JVA) with Jebson. Despite payments made, including a “swapping arrangement” involving other properties, Jebson failed to complete the unit. Buenviaje’s complaints for specific performance and damages against Jebson, Bañez, and Sps. Salonga were consolidated with similar complaints, leading to the case’s progression through various regulatory and judicial bodies, ultimately reaching the Supreme Court.
### Issues:
1. Whether the remedy of specific performance was properly granted in Buenviaje’s favor.
2. Whether Sps. Salonga were solidarily liable with Jebson and Bañez for the fulfillment of the contract.
3. The validity of the “swapping arrangement”.
4. Buenviaje’s liability for moral damages and attorney’s fees to Sps. Salonga.
### Court’s Decision:
1. The Court held the remedy of specific performance was proper as per Buenviaje’s primary request.
2. Sps. Salonga were not solidarily liable as there was no privity of contract between them and Buenviaje.
3. The “swapping arrangement” was deemed valid as there was insufficient evidence to prove it was entered into to defraud Sps. Salonga.
4. The order for Buenviaje to pay moral damages and attorney’s fees to Sps. Salonga was deleted due to a lack of factual basis to establish bad faith on Buenviaje’s part.
### Doctrine:
The Supreme Court reinforced principles regarding specific performance, solidary liability, the validity of contracts, and the award of damages and attorney’s fees. Notably, it clarified that specific performance is a valid remedy when fulfillment of the contract becomes impossible and that solidary liability requires a pre-existing obligation and privity of contract.
### Class Notes:
– **Specific Performance**: A remedy requiring a party to fulfill its contractual obligations.
– **Solidary Liability**: Requires privity of contract and a clear obligation among parties.
– **Swapping Arrangement**: Valid unless proven fraudulent.
– **Moral Damages and Attorney’s Fees**: Require clear evidence of bad faith or damage for awarding.
### Historical Background:
This case illustrates the complex interplay between contracts, real estate development, and legal remedies in the context of Philippine jurisprudence. It highlights the challenges faced in contractual disputes, especially in real estate projects suffering from delays and financial crises.
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