Policarpio G. Concepcion v. Spouses Johnny P. Santos Ii

Summary

This civil law case involves a dispute over a land sale and house construction contract between petitioners and respondent spouses. The Supreme Court affirmed the Court of Appeals' decision that the lot sale was consummated and fully paid, while the house construction was governed by a separate verbal agreement. The key legal issue centered on the application of Article 1191 of the Civil Code regarding the right of rescission. The Court found that petitioner Nequinto breached her construction obligation by failing to complete the house, thus she could not demand full payment or return of the lot. The decision clarifies the distinction between completed land sales and separate construction contracts, emphasizing that the defaulting party cannot invoke rescission rights. The monetary award of P1,425,610.50 was affirmed with 6% annual interest modification.