Case Summary (G.R. No. 168108)

Case Background

This case involves a petition for review on certiorari challenging the decision of the Court of Appeals (CA) that affirmed the ruling of the Regional Trial Court (RTC) regarding a Deed of Conditional Sale between the petitioners, who are the owners of multiple parcels of agricultural land, and the respondent, Goldloop Properties, Inc.

• Parties Involved:
  • Petitioners: Enrique C. Abad, Joseph C. Abad, Ma. Sabina C. Abad, Adelaida C. Abad, Cecilia C. Abad, Victoria C. Abad, Victor C. Abad, Cenon C. Abad, Jr., and Juanita C. Abad
  • Respondent: Goldloop Properties, Inc.

Deed of Conditional Sale

The Deed of Conditional Sale outlines the terms of the sale of agricultural land.

• Key Definitions:

  • Earnest Money: Php 1,000,000.00 paid by the buyer (respondent) as a sign of good faith.
  • First Payment: Php 6,765,660.00 to be paid upon signing the Deed.
  • Full Payment: Remaining balance of Php 27,049,640.00 to be paid by December 31, 1997.

• Important Requirements:

  • The balance payment is contingent upon verification of land area through a site survey.
  • A formal request for an extension must be made one week before December 31, 1997, if payment could not be made.

• Timeframes:

  • Full payment due by December 31, 1997, or within a 30-day extension granted upon request.

• Consequences of Non-Compliance:

  • Failure to comply with the payment leads to forfeiture of the earnest money while the first payment is to be returned to the buyer.

Court Proceedings

The RTC found in favor of the respondent, ruling that the first payment must be returned unconditionally.

• Trial Court Decision:

  • The court held that the first payment was distinct from earnest money and should be returned regardless of the failure to meet conditions set for the balance payment.

• Key Court Findings:

  • The trial court emphasized the unconditional obligation of the petitioners to return the first payment.
  • The court referenced Article 1370 of the Civil Code, asserting that clear contract terms should be enforced as written.

Appeal and Ruling of the Court of Appeals

The petitioners appealed, challenging the trial court’s interpretation of the obligations under the contract.

• CA Decision:

  • The appellate court affirmed the trial court’s ruling, stating that the obligation to return the first payment was unconditional.
  • It clarified that the petitioners’ liability was joint, not solidary.

• Key Points from the CA:

  • The court reiterated the clarity of paragraph 8 of the Deed.
  • It ruled that the petitioners could not demand a period for compliance as the obligation was clearly laid out in the contract.

Supreme Court Ruling

The Supreme Court denied the petition for review, upholding the decisions of both the RTC and CA.

• Final Ruling:
  • The obligation to return the first payment was deemed unconditional without a need for a fixed period.
  • The clear terms of the contract dictated the obligations of both parties.

Key Takeaways

• The Supreme Court confirmed that the obligation to return the first payment was unambiguous and unconditional, affirming the appellate court's interpretation.
• The distinction between e

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Case Syllabus (G.R. No. 168108)

Case Background

• The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
• The petitioners are members of the Abad family, who owned 13 parcels of titled agricultural land totaling 53,562 square meters located in the S.C. Malabon Estate in Tanza, Cavite.
• The respondent, Goldloop Properties, Inc., represented by its President Emmanuel R. Zapanta, entered into a Deed of Conditional Sale with the petitioners on August 29, 1997.
• The agreed purchase price was P34,815,300.00 at a rate of P650.00 per square meter.

Terms of Payment

• Earnest Money: An earnest money of P1,000,000.00 was provided by the buyer on June 30, 1997.
• First Payment: A first payment of P6,765,660.00 was to be paid upon signing of the Deed.
• Full Payment: The remaining balance of P27,049,640.00 was due upon verification of the land area through a site relocation survey and was to be adjusted accordingly.

Conditions and Consequences

• The contract stipulated that if the buyer could not fulfill the payment obligation by December 31, 1997, a formal request for an extension (not exceeding 30 days) should be made.
• If the buyer failed to comply within the extension period, the earnest money would be forfeited, but the first payment would be returned.

Respondent's Communications

• On August 28, 1998, Zapanta communicated willingness to allow the sale to other parties, provided that half of the forfeitable am

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