Congregation of the Religious of the Virgin Mary And/Or the Superior General of the Religious of the Virgin Mary v. Emilio Q. Orola

Summary

The Supreme Court affirmed the Court of Appeals decision ordering specific performance of a land sale contract between the Religious of the Virgin Mary congregation and the Orola family. RVM paid a 10% downpayment of P555,500 for property worth P5,555,000 but later refused to pay the balance, claiming lack of proper authorization and requesting a two-year payment period. The Court distinguished between rescission under Article 1191 (breach of reciprocal obligations) and Article 1381 (economic prejudice), finding this case fell under the former. Since RVM breached the perfected contract by refusing payment despite title transfer, the Court upheld the award of 6% annual interest on the unpaid balance from June 7, 2000, emphasizing that damages are mandatory under Article 1191 regardless of whether rescission or specific performance is granted.