Spouses Miniano B. Dela Cruz v. Ana Marie Concepcion

Summary

This case involves a Contract to Sell dispute between spouses Dela Cruz and Ana Marie Concepcion for a P2,000,000.00 house and lot in Antipolo City. After Concepcion paid the full purchase price ahead of schedule, the parties agreed her remaining obligation for interest and penalties was P200,000.00. When petitioners later claimed a larger amount was due, Concepcion presented a receipt showing payment of the P200,000.00 to Adoracion Losloso. The Supreme Court affirmed lower courts' dismissal of the collection suit, ruling that payment to Losloso was valid under Civil Code Article 1240 since petitioners had expressly authorized her to receive payments. The Court applied Rule 10, Section 5 on amendment to conform to evidence, finding petitioners impliedly consented to try the payment issue by not objecting to respondent's evidence. This case demonstrates principles of contract performance, proper discharge of obligations, and procedural rules on pleading amendments.