Sps. Henry Co v. Court of Appeals

Summary

This case involved a dispute over a real estate purchase contract where Mrs. Adoracion Custodio agreed to buy property from the Co spouses for $100,000. After Custodio failed to meet payment deadlines but made a partial payment of $30,000, the sellers claimed she lost her 'option' to purchase. The Supreme Court held that the parties had entered into a perfected contract of sale, not merely an option contract, based on the presence of all required elements: consent, determinate subject matter, and price certain. The Court ruled that sellers cannot unilaterally rescind a contract without express authorization and that Custodio's offer to complete payment was valid since the contract remained subsisting. The decision required sellers to return the $30,000 payment upon rescission, as rescission creates the obligation to restore parties to their former positions under Article 1385 of the Civil Code.