G.R. No. L-59980 - Taguba vs. Vda. de De Leon

The case involves a petition for review on certiorari regarding a decision from the defunct Court of Appeals.
The original case was filed by Maria Peralta Vda. de De Leon against Berlin Taguba and Sebastiana Domingo for specific performance, preliminary mandatory injunction, and damages.
Berlin Taguba, married to Sebastiana Domingo, owned a residential lot in Cauayan, Isabela, which was partially occupied by lessees, including the private respondent and the Asuncion spouses.
On August 27, 1972, Taguba sold a 400-square-meter portion of the lot to Maria Peralta Vda. de De Leon for P18,000, with specific payment terms outlined in a "Deed of Conditional Sale."

The sale agreement stipulated a down payment of P3,500 upon signing, followed by monthly payments of P1,000 starting September 1972, with the total due by December 31, 1972.
If the full payment was not made by the deadline, the vendee would receive a six-month extension with interest, after which the vendor could increase the purchase price to P50 per square meter.
The private respondent claimed to have paid P12,500 and attempted to pay the remaining P5,500 within the grace period, but Taguba refused to accept the payment.

After failed negotiations mediated by Governor Dy, the private respondent filed a complaint on April 29, 1976, for specific performance against the Tagubas.
The Tagubas admitted the sale but contended that the private respondent had not fulfilled her payment obligations, leading them to sell a portion of the property to the Asuncion spouses.

The lower court ruled in favor of the private respondent, ordering a cadastral survey, execution of a deed of absolute sale for the occupied area, reimbursement of excess payments, and declared a preliminary injunction permanent.
The court did not impose costs on the parties.

The Court of Appeals reversed the lower court's decision, ordering Taguba to execute a deed of absolute sale upon receipt of P7,500 from the private respondent.
It declared the sale to the Asuncion spouses null and void due to the prior sale to the private respondent and mandated reimbursement of the purchase price to the Asuncion spouses.

The Tagubas filed a petition to set aside the appellate court's decision, arguing that the original sale was conditional and that they had the right to rescind the contract due to non-payment.
They contended that the private respondent had failed to comply with the payment terms, justifying their subsequent sale to the Asuncion spouses.

The Supreme Court found that the contract was absolute despite being labeled a "Deed of Conditional Sale."
The absence of a clause reserving title to the vendor until full payment indicated that the sale was complete upon execution.
The court noted that Taguba had not formally rescinded the contract through a notarial act or court filing, which is required under Article 1592 of the New Civil Code.