- Petitioner
- Spouses Nameal
- Respondent
- Spouses Juan
- Citation
- G.R. No. 172346
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Del Castillo, J.
- Decided
- July 24, 2013
Summary
This case involves a Contract to Sell dispute between spouses over a house and lot in Quezon City. The Supreme Court addressed the proper calculation of interest on unpaid installments under such contracts. The key legal issue was whether the buyers' claimed readiness to pay in November 1993 could excuse them from continued interest liability. The Court distinguished between contracts to sell and contracts of sale, emphasizing that non-payment in the former is not breach but failure of a suspensive condition. The Court ruled that mere expression of willingness to pay without actual tender plus consignation does not suspend interest accrual. The decision clarified that under Article 2209 of the Civil Code, delay in monetary obligations requires payment of stipulated or legal interest. The Court also upheld reimbursement obligations with interest when one party pays another's obligations, preventing unjust enrichment. This case provides important guidance on interest calculations, tender of payment requirements, and obligations under contracts to sell real property governed by the Maceda Law.