Raymundo S. de Leon v. Benita T. Ong

Summary

This case involves a double sale of real property where petitioner sold the same three parcels of land in Antipolo, Rizal to two different buyers. The Supreme Court resolved the conflict between lower courts regarding whether the transaction was a contract of sale or contract to sell. The Court ruled it was a contract of sale based on the deed's absolute and irrevocable language and petitioner's acts of delivering keys and authorizing mortgage payments. When petitioner subsequently sold to another buyer and prevented respondent from assuming the mortgage by paying it off himself, the Court applied Article 1186 (condition deemed fulfilled when prevented by obligor) and Article 1544 (double sale rules). Since respondent was first in possession in good faith, she became the lawful owner. The decision balances property rights with contractual obligations, requiring respondent to pay the remaining purchase price while confirming her ownership and awarding damages for petitioner's fraudulent conduct.