G.R. No. 235711 - Pascual vs. Pangyarihan Ang

In January 1989, Romulo Pascual entered into a sale transaction with Encarnacion P. Ang and her children through Antonio Ang.
The transaction involved three parcels of land located in Navotas City, as outlined in the document entitled "Pagpapatunay at Pananagutan."
The document contained specific declarations by Romulo Pascual regarding:

His ownership and management of the three parcels of land located in Tangos, Navotas, Metro Manila.
The description of each lot:

Lot (a): Located on Daang Buenaventura between lots owned or occupied by Protacio Enriquez and Benjamin Dayao.
Lot (b): Located at the end of Daang Buenaventura between lots owned by Benjamin Domingo and Felix San Pedro.
Lot (c): Located at Tabing Ilong adjacent to lots of Benjamin Domingo and Amadeo Cruz.

That the lands were at the time being occupied or leased by Encarnacion P. Ang and her children.
That Romulo Pascual agreed to sell the three parcels for P350.00 per square meter.
A downpayment of P50,000.00 was received, with the understanding that the balance would be paid upon the completion of necessary surveys, plans, documentation, and transfer of titles.

On October 28, 1993, the lot described in paragraph 1(a) was registered under the Original Certificate of Title No. 246 in the names of the respondents.
For the remaining two lots (paragraphs 1(b) and 1(c)), petitioner asserted that:

Consequently, petitioner filed a complaint for the rescission of the "Pagpapatunay at Pananagutan" with a claim for damages before the Regional Trial Court (RTC) of Navotas City on March 2, 2006.
Petitioner additionally claimed:

That the purchase price should be adjusted upward due to changes in the market value of the properties and depreciation of the Philippine peso over time.

That the contractual arrangement required that the title registration in their names be completed before they were obligated to pay the remaining balance.
That petitioner breached the agreement by refusing to register the two lots in the respondents’ names, citing her attempt to demand a higher price than what was originally agreed upon.

Though paragraph 5 of the "Pagpapatunay at Pananagutan" was ambiguous, evidence indicated that it was intended for petitioner to secure title transfer in respondents’ names prior to full payment.
The agreed purchase price of P350.00 per square meter was to be enforced as the contract was the law between the parties.
Petitioner’s claim for an increased price and damages was without merit.

The registration of the first lot in the respondents’ names only occurred after full payment was rendered.
The true intention of the parties, as evidenced by their actions and conduct, should be considered in interpreting the contractual terms.

Payments were made as downpayment and on an installment basis.
The respondents only completed their payment after petitioner secured the title of the first lot in their name.
Respondents' failure to pay the balance was a direct result of petitioner’s noncompliance with the contractual requirement to transfer the titles.

Petitioner’s petition for review on certiorari was eventually filed, challenging the CA decision.

Whether the Court of Appeals erred in not considering the real intention of the contracting parties as evidenced by their conduct, words, and deeds before, during, and after the execution of the contract.
Whether the CA wrongly found that petitioner was at fault and not the injured party, which would justify the rescission of the contract.
Whether it was proper for the CA to impose on petitioner the obligation to secure the transfer of titles in the respondents’ names without clearly addressing the reciprocal obligation on the part of respondents to pay the remaining balance of the purchase price within a reasonable period, including compensation for the use of the subject properties.