Bible Baptist Church Case Digest
Bible Baptist Church Case Digest
Bible Baptist Church Case Digest
Court of Appeals
Topic: Consideration
FACTS
Bible Baptist Church entered into a contract of lease with Spouses Villanueva for a period of 15
years. Upon signing the lease agreement the lessee paid a sum of 84,000 for the purpose of
redemption of said property which mortgaged by the lessor. The lessee has the option to buy the
premises during the lease. When BBC wanted to purchase the property. Spouses Villanueva
contended that there was no consideration that BBC gave then which is why BBC cannot compel
them to sell the property. BBC filed a writ of injunction.
RTC HELD:
The Regional Trial Court found that "[a]ll payments made under the contract of lease were for
rentals. No money [was] ever exchanged for and in consideration of the option." Hence, the
Regional Trial Court found the action of the Baptist Church to be "premature and without basis to
compel the defendant to sell the leased premises."
CA HELD:
1 BBC did not have a consideration and, therefore, did not bind the latter.
2 The option to buy did not have a fixed price agreed upon by the parties for the purchase of the
property
3 BBC is not awarded with damages and attorney’s fees.
ISSUES
1) Whether or not the option to buy given to the Baptist Church is founded upon a consideration;
2) Whether or not by the terms of the lease agreement, a price certain for the purchase of the land
had been fixed; and
3) Whether or not the Baptist Church is entitled to an award for attorney's fees.
SC HELD: Court agrees with as the Court of Appeals, which affirmed the findings of the Regional
Trial Court, that such claim is to be dismissed for lack of factual and legal basis.
WHEREFORE, the Decision and Resolution of the Court of Appeals subject of the petition are
hereby AFFIRMED.
Ratio:
For an option contract to be valid and enforceable against the promissor, there must be a separate
and distinct consideration that supports it. petitioners cannot insist that the P84,000 they paid in
order to release the Villanuevas' property from the mortgage should be deemed the separate
consideration to support the contract of option. They were in fact apportioned monthly rentals for
the year 1985. They posit that their act of advancing the money to "rescue" the property from
mortgage and impending foreclosure, should be enough consideration to support the option. this
Court cannot find that petitioner Baptist Church parted with anything of value, aside from the
amount of P84,000 which was in fact eventually utilized as rental payments. Second, there is no
document that contains an agreement between the parties that petitioner Baptist Church's
supposed rescue of the mortgaged property was the consideration which the parties contemplated
in support of the option clause in the contract.