Silvestre Dignos v. Hon. Court of Appeals

Summary

The Supreme Court resolved a double sale dispute involving the same parcel of land sold first to Jabil in 1965 and subsequently to the Cabigas spouses. The Court held that the original deed of sale was absolute in nature, not a conditional contract to sell, as it contained all essential elements of a valid sale and involved actual delivery through possession and improvements. The Court ruled that no valid rescission of the first sale occurred since petitioners failed to comply with Article 1592 requirements for notarial act or judicial demand. The second sale was declared null and void as the vendors no longer owned the property. This case establishes important precedents on contract interpretation, the distinction between absolute sales and contracts to sell, and proper rescission procedures under Philippine civil law.