- Petitioner
- Gatchalian Realty
- Respondent
- Evelyn M. Angeles
- Citation
- G.R. No. 202358
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Carpio, J.
- Decided
- November 27, 2013
Summary
This landmark real estate case involved the validity of contract cancellation under Republic Act No. 6552 (Maceda Law). GRI, a real estate developer, sought to eject Angeles from property after she defaulted on installment payments for house and lot purchases. The Supreme Court ruled that despite GRI serving proper notice of rescission, no valid cancellation occurred because GRI failed to actually refund the cash surrender value of P574,148.40 to Angeles as mandated by law. The Court emphasized that RA 6552 requires both notarized notice AND actual refund of cash surrender value for effective cancellation. The decision clarifies that developers cannot unilaterally offset rental obligations against refundable amounts, distinguishing developer actions from court-ordered remedies. Angeles was given options to either complete the purchase by paying the balance with interest or accept the cash surrender value with interest to cancel the contracts. This case reinforces buyer protection under the Maceda Law and establishes clear requirements for valid contract cancellation in installment real estate transactions.