Berman Memorial Park v. Francisco Cheng

Summary

This civil case involved a contract dispute between memorial park operator BMPI and lot purchaser Francisco Cheng over payment calculations for upgraded memorial lots. Cheng purchased a 12-Lot for P150,000, then upgraded to 24-Lot for net price of P140,000 after P110,000 credit. Lower courts ruled Cheng overpaid, but the Supreme Court reversed, applying Article 1370 of the Civil Code requiring literal interpretation of clear contract terms. The Court found the Pre-Need Purchase Agreement unambiguously stated P140,000 as the purchase price, rejected Cheng's claim of signing a blank document, and ordered him to pay the outstanding balance. The decision emphasized the primacy of clear contractual language over post-facto assertions and established that parties are presumed to understand contracts they voluntarily sign.