Wenonah L. Marquez-Azarcon v. Housing

Summary

This case involves interpretation of contractual obligations under a real estate purchase agreement. SAGANA and J.M. Builders sold a house and lot to Azarcon, with the balance to be paid through SSS housing loan. When the loan was disapproved partly due to SAGANA's fault, Azarcon offered cash payment but SAGANA demanded interest. The HLURB ultimately required payment of the balance plus monthly rentals forming part of the 'adjusted purchase price.' After Azarcon paid the balance, SAGANA refused to execute the deed without rental payments. The Supreme Court ruled that the agreed purchase price became law between the parties under Civil Code Article 1159, and the rental requirement was merely an interim scheme that became functus officio upon full payment. The decision emphasizes contractual interpretation principles and protects buyers from unilateral contract modifications by sellers.