Delta Motor Sales Corporation v. Niu Kim Duan

Summary

Delta Motor Sales Corporation sold three air-conditioners to defendants under a conditional sale agreement. When defendants defaulted after paying P6,966.00 of the P19,350.00 purchase price, plaintiff repossessed the units through replevin and sought to collect the remaining balance of P6,188.29. The Supreme Court reversed the trial court's award, establishing the important principle that under Article 1484 of the Civil Code, a vendor's remedies in installment sales are alternative, not cumulative. A vendor who chooses to cancel the sale and repossess the goods cannot simultaneously recover the unpaid balance. This decision clarifies the mutually exclusive nature of remedies available to vendors in conditional sales, preventing unjust enrichment and protecting buyers from double recovery by sellers.