Rodolfo Alfonso v. Court of Appeals

Summary

The Supreme Court affirmed the Court of Appeals' reversal of a trial court decision favoring the Alfonso spouses in their action to annul a property sale. The Alfonsos claimed they had a contract of sale with the Chancos for a lot in Laguna, arguing that the Chancos' unilateral cancellation violated Article 1592 of the Civil Code requiring judicial or notarial demand for rescission. However, the Court found that the evidence established only a contract to sell, not a contract of sale, as no formal deed was executed and title was to remain with the Chancos until full payment. Since Article 1592 applies only to contracts of sale and not contracts to sell, the Chancos could validly cancel the agreement upon the Alfonsos' failure to pay the balance within the agreed timeframe. The subsequent sale to the Namits was upheld as valid.