David Reyes (Substituted By Victoria R. Fabella) v. Jose Lim

Summary

This case involves the annulment of a contract to sell real property where the seller David Reyes had already sold the same property to another buyer before completing the original sale to Jose Lim. The Supreme Court upheld the trial court's order requiring Reyes to deposit the P10 million down payment with the court during the pendency of the case, despite deposit not being among the enumerated provisional remedies in the Rules of Court. The Court applied equity jurisdiction to fill the hiatus in the law, preventing unjust enrichment by Reyes who retained the down payment after selling the property to another buyer. The decision established that courts may exercise equity jurisdiction when the prescribed provisional remedies are inadequate, particularly to ensure restitution as required for rescission under Article 1385 of the Civil Code and to prevent unjust enrichment under Article 22.