Garcia v. Court of Appeals

Summary

This case involves a Contract to Sell for five parcels of land in Cavite where the buyers failed to pay the final installment on the due date. The Supreme Court distinguished between contracts to sell and contracts of sale, holding that in contracts to sell, payment is a positive suspensive condition. The Court ruled that the seller validly rescinded the contract due to non-payment and that the Maceda Law did not apply to the subject commercial properties. The decision clarifies that parties may agree to automatic rescission clauses without need for judicial intervention, and that the seller's subsequent sale to another buyer was valid. The case establishes important precedent on the enforceability of automatic rescission provisions in contracts to sell real estate.