Bonifacio Danan v. Spouses Gregorio Serrano

Summary

This case involves a contract to sell real property where buyer Bonifacio Danan failed to complete installment payments under a 1976 agreement with Spouses Serrano. After paying only the first P2,000 of P6,000 total price, Danan filed for specific performance 20 years later in 1998. The Supreme Court affirmed that while the sellers violated RA No. 6552's cancellation requirements (failing to provide proper notice of cancellation by notarial act), the buyer's action was barred by the 10-year prescriptive period under Article 1144 of the Civil Code. The Court distinguished between contracts of sale and contracts to sell, emphasizing that in the latter, title remains with the vendor until full payment. Despite the sellers' procedural violations, the buyer's unreasonable 20-year delay in asserting his rights resulted in prescription. The decision highlights the importance of timely action in contractual disputes and the protective provisions of RA No. 6552 for installment buyers, while affirming that such protections must be invoked within the prescribed limitation periods.