Socorro Vda. de Mondragon v. Hon. Intermediate Appellate Court & the Spouses Manuel

Summary

The Supreme Court resolved whether two separate contracts to sell different parcels of land resulted in novation when the second contract was executed. The Mondragons sold portions of two lots to the Bayonas but later claimed the second contract novated the first when they sold parts of the first lot to third parties. The Court applied Civil Code provisions requiring unequivocal declaration or complete incompatibility for novation. Finding neither express agreement nor incompatibility between the independent contracts, the Court rejected the novation defense. The decision reinforces that novation by presumption is never favored and both contracts remained valid and enforceable. This case clarifies the strict requirements for contractual novation under Philippine civil law.