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  • Case Digest - Agcaoili Vs GSIS

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    Valencia and Valencia Office
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    1. This case involved a dispute between Marcelo Agcaoili and the Government Service Insurance System (GSIS) over a housing contract. Agcaoili was awarded a house and lot by GSIS but the house was incomplete and uninhabitable. GSIS cancelled the contract when Agcaoili refused to pay until completion. 2. The court ruled that specific performance of the original contract could not be required after 20 years as it would result in inequity. Instead, the contract was modified to add the cost of the unfinished house to the land cost, and adjust amortizations based on valuations determined by the court. 3. While GSIS's cancellation was invalid, complete justice required exercising equity jurisdiction

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    Case Digest in Law on Obligations and Contracts

    Original Title

    Case Digest - Agcaoili vs GSIS

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    1. This case involved a dispute between Marcelo Agcaoili and the Government Service Insurance System (GSIS) over a housing contract. Agcaoili was awarded a house and lot by GSIS but the house was incomplete and uninhabitable. GSIS cancelled the contract when Agcaoili refused to pay until completion. 2. The court ruled that specific performance of the original contract could not be required after 20 years as it would result in inequity. Instead, the contract was modified to add the cost of the unfinished house to the land cost, and adjust amortizations based on valuations determined by the court. 3. While GSIS's cancellation was invalid, complete justice required exercising equity jurisdiction

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    © All Rights Reserved
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    43 views1 page

    Case Digest - Agcaoili Vs GSIS

    Uploaded by

    Valencia and Valencia Office
    1. This case involved a dispute between Marcelo Agcaoili and the Government Service Insurance System (GSIS) over a housing contract. Agcaoili was awarded a house and lot by GSIS but the house was incomplete and uninhabitable. GSIS cancelled the contract when Agcaoili refused to pay until completion. 2. The court ruled that specific performance of the original contract could not be required after 20 years as it would result in inequity. Instead, the contract was modified to add the cost of the unfinished house to the land cost, and adjust amortizations based on valuations determined by the court. 3. While GSIS's cancellation was invalid, complete justice required exercising equity jurisdiction

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
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    of 1

    Marcelo Agcaoili, Plaintiff-Appellee vs.

    Government Service Insurance System, Defendant-Appellant.

    G.R. No. L-30056 August 30, 1988

    Narvasa, J.:

    Doctrine:

    1. In reciprocal obligations, neither party incurs in delay if the other does not comply
    or is not ready to comply in a proper manner with what is incumbent upon him.
    2. Specific performance will not be granted if, under the circumstances of the case, the
    result of the specific enforcement of the contract would be harsh, inequitable,
    oppressive, or result in an unconscionable advantage to the plaintiff.
    3. In the exercise of its equity jurisdiction, the Court may adjust the rights of parties in
    accordance with the circumstances obtaining at the time of rendition of judgment,
    when these are significantly different from those existing at the time of generation of
    those rights.

    Facts:

    GSIS approved the application of Agcaoili to purchase a house and lot in GSIS Housing
    Project at Nangka, Marikina, Rizal. He was advised to immediately (within three days)
    occupy the house, which Agcaoili did. However, he could not stay in it and had to leave
    the next day because it was in such a state of incompleteness that civilized occupation
    was not possible. Agcaoili asked a homeless friend, Villanueva, to stay in the premises
    as watchman, pending completion of the construction of the house. GSIS asked Agcaoili
    to pay the monthly amortizations and other fees. Agcaoili paid the first monthly
    installment and the incidental fees, but refused to make further payments until and
    unless the GSIS completed the housing. GSIS cancelled the award and required Agcaoili
    to vacate the premises. Agcaoili instituted a suit in CFI of Manila for specific
    performance and damages. CFI declared the cancellation of award illegal and void. CFI
    ordered GSIS to respect and enforce the award and complete the house in question so
    as to make the same habitable and authorizing GSIS to collect the monthly amortization
    only after said house shall have been completed. GSIS was likewise ordered to pay
    P100.00 as damages and P300.00 as and for attorney's fees, and costs. GSIS sought to
    reverse the decision of CFI.

    Issue:

    Whether or not Agcaoili is entitled to specific performance

    Ruling:

    No. The Court could not require specific performance of the contract according to its
    literal terms, as this would result in inequity. Because 20 years had already passed, to
    compel GSIS to complete the construction at present prices, without modifying the price
    Agcaoili would pay, would be unfair and unrealistic. The situation called for the exercise
    by the Court of its equity jurisdiction, to the end that it may render complete justice to
    both parties.

    The judgment of CFI invalidating the cancellation by GSIS of the award was affirmed by
    the Court. It, however, modified the requirement for GSIS to complete the house.
    Instead, it is ordered that the contract between the parties be modified by adding to the
    cost of the land, as of the time of perfection of the contract, the cost of the house in its
    unfinished state, also as of the time of perfection of the contract, and correspondingly
    adjusting the amortizations to be paid by Agcaoili, the modification to be effected after
    determination by CFI of the value of said house on the basis of the agreement of the
    parties, or if this is not possible by such commissioner or commissioners as the court
    may appoint.

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