Gloria A. Samedra Lacanilao v. Court of Appeals

Summary

Lessees Lacanilao and Cadurnigara claimed a verbal contract to sell from their lessor Encarnacion for P120,000.00, with payment due June 15, 1988. When they failed to pay, Encarnacion sold the property to the Acebos for P145,000.00 through a written deed of absolute sale. Petitioners sued to annul the sale and compel Encarnacion to honor their alleged contract. The Supreme Court denied their petition, holding that in contracts to sell, full payment is a suspensive condition and failure to pay prevents the vendor's obligation to convey title. The Court applied Civil Code provisions on contracts and sales, emphasizing that while equity might favor long-term lessees, positive law provisions cannot be overruled. This case establishes important precedent on the distinction between contracts to sell versus contracts of sale, and the legal consequences of failing to meet payment conditions in property transactions.