Melanie M. Mesina v. Gloria C. Garcia

Summary

This case involves a Contract to Sell executed in 1977 between the Garcia and Mesina families for a 235 square meter lot in Cabanatuan City. After alleged full payment in 1984, respondent Gloria Garcia demanded execution of a Deed of Absolute Sale, which petitioners (Mesina heirs) refused. The Supreme Court affirmed lower courts' decisions ordering execution of the deed, finding that Garcia's cause of action had not prescribed due to continuous written demands that interrupted the prescriptive period under Article 1155 of the Civil Code. The Court applied the doctrine of estoppel, noting that petitioners made admissions under oath in HLURB proceedings acknowledging acceptance of late payments. The case establishes important precedents on prescription interruption in contract enforcement and the application of estoppel in real property transactions involving contracts to sell.