- Petitioner
- Karen Nuñez Vito
- Respondent
- Norma Moises-Palma
- Citation
- G.R. No. 224466
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Caguioa, J.
- Decided
- March 27, 2019
Summary
This case involves a land sale dispute where heirs of Vicentico Nuñez sold their inherited property to Norma Moises-Palma through a Deed of Adjudication and Sale in 1995, but the buyer never paid the P50,000 purchase price despite taking possession and obtaining title. The Supreme Court resolved conflicting lower court decisions by ruling that the transaction was a contract of sale (not dacion en pago as the CA held), which became resolved under Article 1191 due to the buyer's non-payment. The Court distinguished between rescission and resolution in reciprocal obligations, emphasizing that subsequent documents (Promissory Note, Acknowledgment of Debt) and the fact that the original P30,000 loan securing the property was already paid (per AARM) negated any dacion en pago arrangement. The decision reinstated damage awards and ordered annual compensation for the buyer's use of the property, demonstrating the Court's strict enforcement of contractual obligations in property transactions.
Intellegal Wiki · Key Holding
Reversed the CA and RTC and reinstated a modified MTC decision, holding that the transaction was a contract of sale, not dacion en pago, and that the buyer's non-payment of the price resolved the sale under Article 1191 on reciprocal obligations, entitling the sellers to restitution and reasonable compensation for the buyer's use of the property.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.