G.R. No. L-8024 - De la Cruz vs. Legaspi

Plaintiff: Eusebio de la Cruz.
Defendants: Apolonio Legaspi and his wife, Concordia Samperoy.
Transaction: A parcel of land sold in December 1949 for a purchase price of P450.

Plaintiff initiated the suit in November 1950 to compel the defendants to deliver the parcel of land.
The primary complaint alleged the proper execution of the contract of sale, its specific terms, and the defendants’ refusal to accept full payment of P450 tendered by the plaintiff.
Allegations by the plaintiff also centered on the undue retention of the realty by the defendants despite his compliance with the contractual agreement.

The defendants admitted the sale and the stipulated price.
They contended that, prior to the execution of the document of sale on December 5, 1949, the plaintiff had agreed to pay the purchase price immediately after the document was executed the same day.
After notarization of the document and the plaintiff’s possession of it, the defendants claimed that the plaintiff’s subsequent non-payment of P450 rendered the contract void due to lack of consideration and deceit.
The defendants asserted that the contract should be annulled based on the failure of payment as allegedly agreed.

The plaintiff to pay the purchase price of P450 to the defendants.
The defendants, upon receipt of the payment, to deliver possession of the property to the plaintiff immediately.

Plaintiff’s motion for judgment on the pleadings aimed to enforce the contract based on the executed document and the clear term of the sale.
The defendants, joining the motion, maintained their position on the annulment of the sale contract due to the alleged non-payment condition.

The defendants, after failing in a motion for reconsideration, appealed the trial court’s decision.
They assigned seven errors in their printed brief, centering on two principal contentions:

That the trial judge improperly disregarded their allegations in the answer regarding non-payment immediately after execution of the document.
That such non-payment, as stipulated, rendered the contract void for lack of consideration.

Whether the plaintiff’s failure to pay the purchase price “immediately after the document was executed” constitutes a valid ground for annulment of the contract for lack of consideration.
Whether the timing of the payment, as alleged by the defendants, was an essential condition affecting the validity of the contract.
Whether the non-payment default, after the notarization and possession of the document by the plaintiff, automatically renders the contract null and void or merely gives rise to a remedy (such as the claim for interest or rescission).
Whether the trial court properly considered and adjudicated the allegations contained in both the complaint and the defendants’ answer.