- Petitioner
- Rhodora G. Blas
- Respondent
- Linda Angeles-Hutalla
- Citation
- G.R. No. 155594
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Callejo, Sr., J.
- Decided
- September 27, 2004
Summary
This case involves a real estate sale dispute between Filipino-American Linda Angeles-Hutalla and Filipino citizen Rhodora Blas over a Mandaluyong property. Multiple conflicting sale documents were executed: an unnotarized Philippine deed for P250,000 and US contracts for US$40,000 with installment terms. Blas made partial payments but failed to complete the US$7,000 installment due January 1989. She sued for specific performance and title delivery, while Hutalla sought rescission. The Supreme Court affirmed lower courts' findings that the US contracts (deed of sale and REPCRD) were the binding agreements. Blas's failure to complete payment entitled Hutalla to rescission. The Court rejected Blas's procedural objections to evidence admissibility, finding them waived by her subsequent invocation of the Maceda Law, which implicitly admitted the contracts' validity. The case demonstrates principles of contract interpretation, evidence waiver, and sales law remedies.