Memorandum for Defendant
Republic of the Philippines
COURT OF APPEALS
Manila
SECOND DIVISION
RAUL GERONIMO and ANNA GERONIMO Plaintiff-Appellee,
CIVIL CASE NO. 190211
-versus -
PETER PASCUAL Defendant-Appellant,
x-----------------------------------x
MEMORANDUM
Defendant-appellant, Peter Pascual, through counsel, in compliance with the Honorable Court’s order,respectfully submits this Memorandum Prefatory Statement
Plaintiff-appellee RAUL GERONIMO and ANNA GERONIMO in the instant case claims, with the lower Court’s sanction, that there should be an annulment of the Deed of Sale, saying that the Contract of Sale of the Condominium Unit has not been consummated.
Defendant-appellant PETER PASCUAL, however, categorically denies the allegations and that the sale of the condominium unit is valid because he was able to talk to Raul Geronimo and he handed to him the manager’s check worth 2 Million Pesos.
STATEMENT OF FACTS/CASE
1. Defendant, Peter Pascual, single and a sales manager, has been friends with Raul Geronimo, the husband of plaintiff Anna Geronimo since college.
2. Sometime in January 2009, when defendant visited the condominium unit of the plaintiff, the latter told the former of their plan to sell said property. Immediately after, defendant told the spouses Geronimo that he will buy the said condo unit should they finally decide to sell the same.
3. In April 2009, plaintiff called defendant informing him that they have finally found a house and asked him if he was still interested to buy the condo unit for Two million Pesos (P2, 000, 000.00). Defendant immediately replied “yes” to plaintiff and shall back when the Deed of Sale and Manager’s check were ready.
4. In May 2009, plaintiff went to the United States to give birth.
5. In June 2009, defendant met up with Raul Geronimo. The latter signed the Deed of Sale after the former handed to
COURT OF APPEALS
Manila
SECOND DIVISION
RAUL GERONIMO and ANNA GERONIMO Plaintiff-Appellee,
CIVIL CASE NO. 190211
-versus -
PETER PASCUAL Defendant-Appellant,
x-----------------------------------x
MEMORANDUM
Defendant-appellant, Peter Pascual, through counsel, in compliance with the Honorable Court’s order,respectfully submits this Memorandum Prefatory Statement
Plaintiff-appellee RAUL GERONIMO and ANNA GERONIMO in the instant case claims, with the lower Court’s sanction, that there should be an annulment of the Deed of Sale, saying that the Contract of Sale of the Condominium Unit has not been consummated.
Defendant-appellant PETER PASCUAL, however, categorically denies the allegations and that the sale of the condominium unit is valid because he was able to talk to Raul Geronimo and he handed to him the manager’s check worth 2 Million Pesos.
STATEMENT OF FACTS/CASE
1. Defendant, Peter Pascual, single and a sales manager, has been friends with Raul Geronimo, the husband of plaintiff Anna Geronimo since college.
2. Sometime in January 2009, when defendant visited the condominium unit of the plaintiff, the latter told the former of their plan to sell said property. Immediately after, defendant told the spouses Geronimo that he will buy the said condo unit should they finally decide to sell the same.
3. In April 2009, plaintiff called defendant informing him that they have finally found a house and asked him if he was still interested to buy the condo unit for Two million Pesos (P2, 000, 000.00). Defendant immediately replied “yes” to plaintiff and shall back when the Deed of Sale and Manager’s check were ready.
4. In May 2009, plaintiff went to the United States to give birth.
5. In June 2009, defendant met up with Raul Geronimo. The latter signed the Deed of Sale after the former handed to