Heirs of Severina San Miguel v. The Honorable Court of Appeals

Summary

This case involves a dispute between heirs over land transfer obligations under a compromise agreement. Severina San Miguel's heirs and Dominador San Miguel's heirs entered into a kasunduan requiring payment of P1.5M for two titled lots and P300,000 for an untitled lot, with title delivery conditioned on full payment. Dominador paid P1.5M but refused to pay P300,000, claiming Severina's heirs lacked proof of ownership over the untitled lot, which was declared in another person's name. The Supreme Court held that Severina's heirs could not compel payment for property they could not legally transfer, as this would constitute unjust enrichment. Since the titled lots were fully paid, the heirs were ordered to surrender the certificate of title. The Court applied Civil Code provisions requiring vendors to have the right to transfer ownership and deemed the condition for additional payment impossible to fulfill.