Francisco Gutierrez Repide v. Ivar O. Afzelius

Summary

This landmark 1918 Supreme Court case established the vendor's right to specific performance in real estate contracts under Philippine civil law. Francisco Gutierrez Repide sued spouses Ivar and Patrocinio Afzelius for specific performance after they failed to complete a P10,000 land purchase agreement, claiming financial inability. The Court of First Instance dismissed the case, finding specific performance impracticable due to defendants' lack of funds. The Supreme Court reversed, applying Civil Code provisions and the principle of contractual mutuality. The court held that vendors have equal rights to specific performance as vendees, and that mere pecuniary inability does not excuse contractual performance. The decision harmonized civil law doctrine with common law equity principles, establishing important precedent for enforcing bilateral real estate contracts in the Philippines through judicial compulsion rather than just damages.