- Petitioner
- Congregation of the Religious of the Virgin Mary And/Or the Superior General of the Religious of the Virgin Mary
- Respondent
- Emilio Q. Orola
- Citation
- G.R. No. 169790
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Nachura, J.
- Decided
- April 30, 2008
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.
Intellegal Wiki · Key Holding
Affirmed the grant of specific performance with 6% interest, holding that the buyer's refusal to pay the balance despite transfer of title was a breach of reciprocal obligations governed by Article 1191 (not the Article 1381 rescission for economic prejudice), and that damages, including interest, are mandated under Article 1191 whether rescission or specific performance is chosen.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.