Je Froilan M. Clerigo v. Spouses Charlie Dinapo

Summary

This case involves an unlawful detainer dispute where petitioners Je Froilan M. Clerigo and Ma. Cristina T. Rodriguez entered a property under a contract to sell but failed to comply with their obligations, leading to termination of the agreement. Despite termination, they remained in possession, prompting respondent spouses to file an unlawful detainer case. The Court of Appeals ruled in favor of respondents, finding all elements of unlawful detainer present and clarifying that Article 1191 rescission provisions do not apply to contracts to sell. The Supreme Court denied petitioners' appeal and affirmed the CA decision, emphasizing that in contracts to sell, non-payment is not a breach but an event preventing the vendor's obligation to convey title from becoming effective. The case establishes important jurisprudence on the distinction between rescission of reciprocal obligations and termination of contracts to sell due to non-fulfillment of suspensive conditions.