Heirs of Cayetano Pangan v. Spouses Rogelio Perreras

Summary

The Supreme Court affirmed the validity and enforceability of a real property sale contract between deceased Consuelo Pangan and spouses Perreras, despite objections from Pangan's heirs (co-owners). The Court held that a perfected contract existed based on the payment and receipt of P20,000 earnest money, with no evidence the agreement was conditioned on the heirs' consent. Under Article 493 of the Civil Code, Consuelo had the absolute right to dispose of her pro indiviso share independently of other co-owners. The Court ruled that the respondents' one-day delayed payment was cured under Article 1592 of the Civil Code and the Maceda Law's grace period provisions, making the characterization of the contract as sale versus contract to sell irrelevant. The decision reinforces co-owners' rights to alienate their shares and the legal significance of earnest money in contract perfection under Philippine civil law.