- Petitioner
- Fil-Estate Properties
- Respondent
- Spouses Conrado
- Citation
- G.R. No. 185798
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Perez, J.
- Decided
- January 13, 2014
Summary
The Supreme Court affirmed the refund order for respondent spouses who purchased a condominium unit but did not receive the completed property due to construction stoppage. Petitioner developers claimed the 1997 Asian financial crisis excused their non-performance as a fortuitous event. The Court rejected this defense, citing precedent that the financial crisis was not unforeseeable for real estate enterprises engaged in pre-selling. Under P.D. 957 and Civil Code Article 1191, buyers are entitled to rescission and refund when developers fail to complete projects within the prescribed time. The Court modified the interest rate from 12% to 6% per BSP circular, while sustaining awards for moral damages, attorney's fees, and administrative fines for the developers' bad faith breach.