Spouses Desiderio v. Spouses Emmanuel

Summary

This case involves a property dispute where Spouses Domingo entered into an agreement with Spouses Manzano to purchase property for P900,000.00 but failed to complete payment by the March 2001 deadline. The property was subsequently sold to Aquino. The Supreme Court distinguished between a contract of sale and contract to sell, ruling the agreement was the latter where title remains with seller until full payment. Since the Domingos failed to pay completely, no sale occurred in their favor, making Article 1544 on double sales inapplicable. The Court affirmed there was only one valid sale - to Aquino - and ordered reimbursement of amounts paid by the Domingos to prevent unjust enrichment. The case clarifies that specific performance is improper in contracts to sell before full payment, and subsequent buyers cannot be deemed in bad faith when purchasing from owners who retain valid title.