- Petitioner
- Development Bank of the Philippines
- Respondent
- Romeo Teston
- Citation
- G.R. No. 174966
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Carpio-Morales, J.
- Decided
- February 14, 2008
Summary
DBP sold land to Teston under a conditional sale agreement. When Teston defaulted, DBP rescinded the contract. Teston claimed agrarian reform law assumed his obligations and prevented rescission, but DARAB and higher courts rejected this defense. The Court of Appeals ordered DBP to return P1,000,000 downpayment based on rescission principles, but the Supreme Court reversed this ruling. The SC held that ordering restitution violated due process because the issue was not raised in lower proceedings, denying DBP the opportunity to present evidence. The case establishes that courts cannot grant relief beyond what is pleaded and that proper evidence rules must be followed even in equity considerations.
Intellegal Wiki · Key Holding
A court cannot grant relief on an issue not raised in the trial court, as it violates due process; and documents that are mere photocopies not formally offered in evidence are inadmissible under Rules 130 and 132.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.