Enrico S. Eulogio v. Spouses Clemente Apeles

Summary

Enrico Eulogio sued spouses Apeles for specific performance of a Contract of Lease with Option to Purchase over real property in Quezon City. The RTC initially ruled for Enrico, finding the contract valid. However, the Court of Appeals reversed, questioning the authenticity of Luz Apeles' signature since she was proven to be in the USA when the contract was allegedly signed. The Supreme Court affirmed the Court of Appeals, noting Enrico's contradictory testimony undermined his credibility. Crucially, the Court ruled that even if the contract were valid, the option contract was unenforceable under Civil Code Article 1479 because it lacked separate consideration distinct from the purchase price. The case establishes that option contracts must be supported by independent consideration to be binding, and that notarized documents can be challenged with clear and convincing contrary evidence.