Spouses Michael Uy & Bonita Uy v. Eduardo Ariza

Summary

Spouses Uy purchased land portions from the Arizas with option to choose specific areas, but were later evicted by the Delgados who claimed prior ownership. The Supreme Court held that the Uys' action for specific performance was improper since the vendors had delivered possession and the issue was eviction by third parties. The proper remedy was warranty against eviction under Civil Code Article 1548, but this required the vendor to be summoned in the eviction suit, which the Uys failed to do. The Court emphasized that the Uys could have filed a third-party complaint against the vendors in the unlawful detainer case. The decision clarifies the distinction between failed delivery requiring specific performance versus successful delivery followed by eviction requiring warranty enforcement.