Virgilio R. Romero v. Hon. Court of Appeals

Summary

This case involves a conditional sale of land where the vendor failed to eject squatters within the contractually stipulated 60-day period. When the vendor sought to rescind the contract and return the P50,000.00 downpayment, the buyer refused and demanded performance of the sale. The Supreme Court ruled that the vendor, having breached her contractual obligation, was not entitled to rescind the contract. The ejectment of squatters was merely a condition that triggered the buyer's obligation to pay the balance, and the buyer's waiver of this condition and continued willingness to proceed with the sale demonstrated his good faith. The Court emphasized that under Article 1191 of the Civil Code, only the injured party may seek rescission, and here the vendor was the breaching party, not the injured party. The decision clarifies the nature of conditional obligations in sale contracts and the rights of parties when conditions are not timely fulfilled.