Corinthian Realty v. Hon. Court of Appeals

Summary

Corinthian Realty sought specific performance of a conditional sale agreement for real property co-owned by several individuals. The company failed to pay the balance of P335,159 within the 90-day period stipulated in the deed, despite making initial payments. The Supreme Court denied the petition, holding that only the pro-indiviso shares of co-owners who actually signed the deed were affected by the sale. The Court applied Article 493 of the Civil Code, ruling that each co-owner can only sell his undivided share. Since petitioner failed to pay within the conditional period, the vendors' obligation to execute an absolute deed never arose under Article 1181. The decision reinforces the principle that in conditional sales, compliance with stated conditions precedent is mandatory for the contract's fulfillment, and that co-ownership sales affect only the shares of consenting co-owners.