G.R. No. 227070 - Adamson University Faculty and Employees Union vs. Adamson University

Petitioners are the wife and children of the late Julio Garcia, heirs to a portion of a 90,655 square-meter property denominated as Lot 1642 of the Sta. Rosa Estate in Barangay Caingin, Sta. Rosa, Laguna, covered by TCT No. RT-1076.
Lot 1642 was co-owned by Vicente de Guzman (share A12), Enrique Hemedes (share A14), and Francisco Alibudbud (father of Maria Alibudbud, share A14).
Julio Garcia had no separate registered title but had tax declarations in his name covering 21,460 square meters, representing his grandfather's share.

On July 5, 1984, petitioners (heirs of Julio Garcia) and respondent Federico Briones entered into a Kasunduan for the sale of the 21,460 square-meter portion for P150,000.00.
Respondent paid P65,000.00 upon execution of the contract, with the balance of P85,000.00 payable within six months, conditioned on the delivery of the title.
Petitioners informed respondent that TCT No. RT-1076 was with their cousin Conchalina Alibudbud, who owned a larger share, having purchased Vicente de Guzman’s portion.
The contract stipulated:

The full price of P150,000.00 with an initial payment of P65,000.00 and the balance payable within six months only upon delivery of the “kaukulang titulo ng lupang nabanggit” (appropriate title of the property).
Petitioners responsible for costs related to notarization, taxes, and registration.

Respondent took possession and paid P58,500.00 in various installments, but later refused to pay the balance citing failure of petitioners to deliver a separate title in Julio Garcia's name.
Petitioners filed suit for rescission of the contract, recovery of possession, and damages, alleging respondent’s obligation to pay the balance upon delivery of TCT No. RT-1076, which they claimed to have offered.
Respondent counterclaimed for damages due to non-delivery of a separate title.
The Regional Trial Court (RTC) rescinded the Kasunduan, ordered respondent to return possession, and directed petitioners to refund payments with interest. The Court found respondent was merely lacking in funds and was not justified to withhold payment because of non-delivery of title.
The Court of Appeals reversed the RTC, ruled that delivery of a separate title was a condition precedent to payment, and dismissed the complaint. The counterclaim was dismissed for lack of malice, recognizing a genuine dispute over contract interpretation.
Petitioners filed a petition for review on certiorari before the Supreme Court contesting the Court of Appeals’ ruling and raising an additional issue regarding the respondent’s failure to submit a certification against forum shopping.

Whether payment of the balance of the purchase price was conditioned upon delivery of a separate title in the name of Julio Garcia.
Whether petitioners were entitled to rescind the Kasunduan for respondent’s failure to complete payment of the purchase price.
Whether the Court of Appeals should have dismissed respondent’s appeal for failure to comply with Circular No. 28-91 on certification of non-forum shopping.