South Rich Acres v. Spouses Roy

Summary

This case involves a property dispute over a 35-square-meter lot in Las Piñas City. SRAI assigned the property to contractor Juangco through dacion en pago for construction services. Juangco subsequently sold the property to respondent spouses Comia, who fully paid Php410,000.00 (Php260,000.00 cash plus Php150,000.00 unpaid wages). Despite full payment and delivery of the owner's duplicate title, SRAI refused to execute the deed of sale. The Supreme Court applied Civil Code provisions on contracts and dation en pago, finding two valid executed contracts. The Court held that Juangco was estopped from denying full payment based on her judicial admission, and that respondents now stand in place of Juangco regarding SRAI's obligation. The decision affirmed the Court of Appeals' order compelling execution of the deed of absolute sale, rejecting SRAI's claims about easement conditions as extraneous to the sales agreements.