G.R. No. L-25494 - Sanchez vs. Rigos

On April 3, 1961, Nicolas Sanchez (plaintiff) and Severina Rigos (defendant) executed an instrument titled “Option to Purchase,” whereby Rigos “agreed, promised and committed” to sell to Sanchez a parcel of land in the barrios of Abar and Sibot, San Jose, Nueva Ecija (TCT No. NT-12528), for ₱1,510.00, exercisable within two years, subject to lapse if Sanchez failed to exercise the option in that period.
Sanchez “agreed and conformed” with the conditions but the instrument did not recite any consideration distinct from the sale price; both parties understood it as a mere option.

Within the two-year period, Sanchez made several tenders of ₱1,510.00, all of which Rigos rejected.
On March 12, 1963, Sanchez deposited the amount with the Court of First Instance of Nueva Ecija (judicial consignation) and filed an action for specific performance and damages.

Rigos filed an answer admitting some allegations, denying others, and raised as special defense that the unilateral promise lacked consideration distinct from the price and was void under Article 1479 of the Civil Code.
On February 11, 1964, both parties jointly moved for judgment on the pleadings.
On February 28, 1964, the lower court rendered judgment for Sanchez, ordering Rigos to accept the consigned sum and execute the deed of conveyance, and awarded ₱200.00 attorney’s fees plus costs. Rigos appealed; the Court of Appeals certified the case to the Supreme Court as presenting a question purely of law.

Whether the unilateral “Option to Purchase” is a reciprocally demandable promise under Article 1479 of the Civil Code, despite lacking consideration distinct from the price.
Whether an accepted unilateral promise to sell, unsupported by separate consideration, may be withdrawn before acceptance or, upon acceptance, constitutes a binding bilateral contract of sale.