Virgilio A. Taok v. Supremido Conde

Summary

This case involves a land sale dispute where petitioner Virgilio Taok sought rescission of a P1,000,000.00 sale agreement with respondents Supremido and Raul Conde due to their failure to pay monthly installments. After receiving P165,000.00 down payment in January 2007, respondents failed to pay any of the required P20,000.00 monthly installments for over two years. The RTC granted rescission, but the CA reversed, ordering specific performance based on alleged oral modifications to the payment terms. The Supreme Court ultimately reversed the CA, applying the parol evidence rule to reject claims of oral contract modification and finding substantial breach warranting rescission. The Court ordered rescission of the Agreement and restitution of the down payment with interest, emphasizing that non-payment of 83.5% of the purchase price constituted substantial breach of a reciprocal contract under Article 1191 of the Civil Code.