Teresita E. Pascual v. Encarnacion Pangyarihan Ang

Summary

This case involves interpretation of a 1989 real property sale contract between Romulo Pascual and the Ang family covering three lots in Navotas City. The dispute centered on paragraph 5 of their agreement which ambiguously stated when titles should be transferred and payment completed. Petitioner Teresita Pascual, as Romulo's widow, sought contract rescission claiming non-payment, while respondents argued petitioner breached by refusing to transfer titles first. The Supreme Court applied Civil Code articles on contract interpretation, examining the parties' conduct regarding the first lot where title transfer preceded full payment. The Court found this established the parties' true intention that titles should be transferred before full payment. Since petitioner failed to transfer the remaining two lots' titles, she was not the injured party and thus not entitled to rescission. The Court ordered mutual performance: petitioner must transfer titles and respondents must pay the balance within 30 days thereafter.