Case Summary (G.R. No. 96053)
Key Dates
- May 28, 1975: execution of the deed of conveyance for P50,000.
- May 29, 1975–November 3, 1979: payments made by vendee.
- January 22, 1981: consignment of P18,520.00 in court.
- September 12, 1984: Regional Trial Court judgment in favor of Leyva.
- March 3, 1993: Supreme Court decision.
Applicable Law
- 1987 Philippine Constitution.
- Civil Code of the Philippines:
• Article 1186 (constructive fulfillment)
• Article 1191 (rescission)
• Article 1235 (estoppel by acceptance of performance)
• Article 1256(4) (effect of consignation) - Rules of Court, Rule 39, Section 10 (clerk’s authority to execute deed upon default).
Facts
- Juan Galicia, Sr. and Celerina Labuguin agreed to sell an undivided one-half interest in a Nueva Ecija parcel to Leyva for P50,000, payable in four installments: P3,000 on execution; P10,000 within ten days; assumption of a P10,000 Philippine Veterans Bank debt; and P27,000 within one year.
- Leyva paid the P3,000 and tendered P9,707 on the second installment, the bank obligation partially (P6,926.41), and made no direct payment on the P27,000 balance. Celerina Labuguin covered the shortfall on the bank loan.
- Petitioners never rescinded the contract but accepted irregular and delayed payments up to November 3, 1979.
- Leyva filed for specific performance. The trial court and Court of Appeals ruled in his favor, applied Articles 1186 and 1235, and ordered execution of the deed of sale, an accounting of payments, refund of overpayment, attorney’s fees, and costs.
Issue
Whether Leyva’s performance—through piecemeal, post-grace-period payments and consignment—satisfied the vendee’s obligations under the contract, thus barring petitioners from rescinding and entitling him to specific performance.
Ruling
The petition is dismissed. The Supreme Court affirms the Court of Appeals’ decision with a slight amendment to paragraph 4 of the dispositive, confirming Leyva’s entitlement to specific performance, reimbursement of overpayment, interest, attorney’s fees, damages, and costs.
Reasoning
- Constructive Fulfillment (Art. 1186): In a reciprocal obligation, each party is both obligor and obligee. Petitioners, as vendors, impeded Leyva’s assumption of the bank loan by paying part of it themselves; Leyva’s partial payment nonetheless met the spirit of the stipulation.
- Estoppel by Acceptance (Art. 1235): Petitioners knowingly accepted delayed and incomplete payments without protest, thereby waiving any right to rescind under Article 1191. Acceptance of benefits arising from overdue accounts converts irregular performance into full compliance.
- Admission of Full Payment: Josefina Tayag’s in-court admission that the second installment of P10,000 was fully paid binds the petitioners, precluding denial of that payment.
- Consignation (Art. 1256[4]): Leyva’s deposit of P18,520.00 into court discharged his obligation where multiple heirs claimed entitlement to collection. Co
Case Syllabus (G.R. No. 96053)
Procedural History
- May 28, 1975: Juan Galicia, Sr. and Celerina Labuguin execute a deed of conveyance covering an undivided one-half portion of a lot in Poblacion, Guimba, Nueva Ecija in favor of Albrigido Leyva for ₱50,000.00 under four staggered payment conditions.
- Private respondent (vendee) seeks specific performance after heirs of Juan Galicia, Sr. (petitioners) refuse to execute the final deed of sale.
- Regional Trial Court, Branch 31, Guimba, Nueva Ecija, grants specific performance and orders execution of deed, assessment of attorney’s fees, damages, refund and consigned sums.
- Court of Appeals modifies the monetary computations but affirms the grant of specific performance.
- Supreme Court (G.R. No. 96053) affirms with slight modification to the monetary disbursements.
Facts of the Case
- Contract Price: ₱50,000.00 for undivided one-half of Lot No. 1130, Guimba Cadastre (TCT No. NT-120563).
- First Installment: ₱3,000.00 paid upon execution (acknowledged).
- Second Installment: ₱10,000.00 due within ten days—petitioners admit receipt of ₱9,707.00 in piecemeal payments from May 29, 1975 to November 3, 1979; private respondent claims full ₱10,000.00 paid (admission by Josefina Tayag).
- Third Installment: ₱10,000.00 representing vendors’ indebtedness to Philippine Veterans Bank—private respondent pays ₱6,926.41; sister-vendor Celerina Labuguin pays ₱3,778.77.
- Fourth Installment: ₱27,000.00 due within one year—private respondent pays ₱13,908.25 (August 8, 1975 to November 3, 1979) and later consigns ₱18,520.00 in court; no direct payment to petitioners.
Issues Presented
- Whether private respondent fully complied with the four payment conditions of the deed of