G.R. No. 96053 - Tayag vs. Court of Appeals

On May 28, 1975, Juan Galicia, Sr. and Celerina Labuguin executed a deed of conveyance in favor of Albrigido Leyva covering an undivided one-half portion of Lot No. 1130, Guimba Cadastre, Nueva Ecija, for P50,000.00.
The sale contract provided:

P3,000.00 paid upon execution;
P10,000.00 due within ten days;
Assumption by vendee of the vendors’ P10,000.00 indebtedness with the Philippine Veterans Bank;
Balance of P27,000.00 due within one year.

The P3,000.00 initial installment was duly received.
Of the P10,000.00 second installment, only P9,707.00 was tendered and accepted by the heirs of Juan Galicia, Sr. on various dates between May 29, 1975 and November 3, 1979.
On the third condition, Leyva paid P6,926.41 to the Philippine Veterans Bank; Celerina Labuguin paid the remaining P3,778.77.
No payment was made by Leyva on the P27,000.00 balance; he eventually consigned P18,520.00 with the RTC.

Leyva filed a complaint for specific performance before the Regional Trial Court (RTC), Branch 31, Guimba, Nueva Ecija.
The RTC, under Judge Rilloraza, ruled for Leyva: it applied constructive fulfillment (Art. 1186, Civil Code) and estoppel by acceptance of piecemeal payments (Art. 1235, Civil Code), ordered conveyance and detailed the disbursement of consigned funds.
On appeal, the Court of Appeals agreed in principle but modified the computation of unpaid balance and refund: it found P13,908.25 paid on the fourth installment up to November 3, 1979, leaving P13,091.75; added P3,778.77 reimbursement to vendors, totaling P16,870.52 unpaid, and awarded Leyva an excess refund of P1,629.48 from the P18,500.00 consigned.

Whether the vendee substantially complied with the payment conditions of the deed of sale.
Whether the heirs’ acceptance of delayed and piecemeal payments precludes their right to rescind.
Whether constructive fulfillment under Article 1186 of the Civil Code and estoppel under Article 1235 apply to the partial payments.
Whether Leyva’s consignation of P18,520.00 validly extinguished his obligation on the unpaid balance.