Leocadia Angelo v. Cipriano Pacheco

Summary

This case involved a dispute over warranty obligations in a real property sale. Leocadia Angelo sold land to Cipriano Pacheco with an express waiver of warranty in case of eviction. When the land's title was later invalidated and Pacheco was evicted, he refused to pay the remaining purchase price, claiming the warranty waiver was invalid due to Angelo's alleged bad faith. The Supreme Court affirmed the trial court's ruling that the warranty waiver was valid and binding. The Court found no evidence of bad faith by the vendor at the time of sale, and noted that even if there was misrepresentation in registration proceedings, this did not relate to the eviction itself. The Court also held that Pacheco's failure to notify the vendor during eviction proceedings released her from warranty obligations under Article 1481 of the Civil Code. This case establishes important precedent on the validity of warranty waivers in property sales and the requirements for invoking warranty protection.