Fidela del Castillo Vda. de Mistica v. Spouses Bernardino Naguiat

Summary

This Supreme Court case addresses the requirements for rescission of a contract of sale under Article 1191 of the Civil Code. Petitioner sought to rescind a land sale contract due to respondents' failure to pay the balance within ten years. The Court held that rescission requires substantial and fundamental breach, which was absent here since the contract explicitly allowed payment with 12% interest even after the stipulated period. The Court emphasized that contractual stipulations constitute the law between parties and must be enforced as written. The decision clarifies that registration of land title does not determine rescission rights and that title issues cannot be resolved through collateral attack in rescission proceedings. The case establishes important precedent on when contractual breaches warrant rescission and the relationship between land registration and contractual remedies.