Francisco Abelarde v. Maria Lopez

Summary

Francisco Abelarde and Adela Araullo sold sugar haciendas to Maria Lopez through a 'dacion en pago' for P60,000.00 to satisfy a foreclosure judgment. They later sued claiming the sugar quota was not included in the sale. The Supreme Court affirmed the trial court's decision that the sugar quota was included, based on an express waiver clause in the deed and the legal principle under Act No. 4166 that sugar allotments are improvements attaching to the land. The Court held that sugar lands would be practically useless without the allotment, and that appellants' refusal to sign required transfer forms violated their contractual obligations. The decision emphasizes that parties cannot take advantage of their own wrong to evade contractual commitments.