**Cirilo Paredes vs. Jose L. Espino, G.R. No. L-25961**
### Facts
**Step-by-Step Series of Events:**
1. **Negotiation:** Cirilo Paredes (Plaintiff-Appellant) and Jose L. Espino (Defendant-Appellee) entered into negotiations for the sale of Lot No. 67 of the Puerto Princesa Cadastre at P4.00 per square meter.
2. **Agreement by Correspondence:** The agreement was concluded through a series of letters and a telegram. In a letter dated May 18, 1964, Espino confirmed he and his wife accepted Paredes’ offer, including a telegram notifying his arrival for the transaction’s formalization.
3. **Refusal to Execute Deed:** Upon arriving in Puerto Princesa, Espino refused to execute the deed of sale, despite Paredes being ready to pay.
4. **Demand by Paredes:** Persistent refusal by Espino continued even after written demands were made by Paredes.
5. **Filing of Complaint:** Paredes filed a complaint in the Court of First Instance of Palawan seeking specific performance and damages.
6. **Motion to Dismiss:** Espino moved to dismiss the complaint on grounds that it lacked a cause of action and was unenforceable under the Statute of Frauds.
7. **Opposition to Motion:** Paredes opposed the motion, attaching the aforementioned letter (May 18, 1964) and telegram as evidence.
**Procedural Posture:**
1. **Court of First Instance:** The Court dismissed the complaint, concluding no written contract existed, thus rendering it unenforceable per Article 1403 of the Civil Code of the Philippines.
2. **Appeal to Supreme Court:** Paredes appealed the dismissal to the Supreme Court, arguing that the letters and telegram constituted a sufficient memorandum under the Statute of Frauds.
### Issues
1. **Statute of Frauds:** Whether the agreement made by letter and telegram was enforceable under the Statute of Frauds, given that it was not formalized in a single written contract.
2. **Prima Facie Case:** Whether the complaint sufficiently alleged a cause of action based on the documents supplied.
### Court’s Decision
**Issue 1: Statute of Frauds**
– **Analysis:** The Supreme Court ruled that the Statute of Frauds, per Article 1403(2) of the Civil Code, does not require the contract itself to be in a single writing but can be satisfied by a series of writings that together constitute a memorandum of the agreement’s essential terms. The documents presented were deemed sufficient to meet this requirement as they included the essential terms of the sale: property details, purchase price, and parties’ acknowledgment of the agreement.
– **Resolution:** The agreement constituted through correspondence and telegram was enforceable under the Statute of Frauds.
**Issue 2: Prima Facie Case**
– **Analysis:** The documents provided by Paredes, being signed by Espino, were prima facie evidence of the transaction’s validity, warranting a trial to verify their authenticity and enforceability.
– **Resolution:** The Court determined the lower court should not have dismissed the complaint without a trial to examine the existence and authenticity of the written memoranda.
### Doctrine
1. **Sufficient Memorandum Doctrine:** A contract may be taken out of the Statute of Frauds by a series of writings that together contain all essential terms of the transaction, even if not formalized in a single document.
2. **Prima Facie Validity:** Documents that prima facie evidence a contract’s essential terms and are signed by the party charged are enough to satisfy the Statute of Frauds, pending trial verification of authenticity.
### Class Notes
1. **Statute of Frauds (Art. 1403, Civil Code):** Contracts involving the sale of real property need a written note or memorandum signed by the charged party to be enforceable.
– **Cited Precedents:**
– Berg vs. Magdalena Estate Inc., 92 Phil. 110, 115: A sufficient memorandum may be contained in multiple documents.
– Shaffer vs. Palma, G.R. No. L-24115: Authenticity of writings need only be established at trial.
2. **Enforceability:** The presence of essential terms and acknowledgement by both parties in correspondences suffices to meet the Statute of Frauds requirements.
### Historical Background
The case reflects early 1960s legal principles in the Philippines concerning the enforceability of oral contracts substantiated by written memoranda under the Statute of Frauds. It emphasizes judicial tendency to give weight to practical business practices involving correspondence, reinforcing contractual obligations when proper documentation is evident, thus aligning with global contract law trends focused on upholding good faith and commercial predictability.
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