Maria P. Vda. de Jomoc v. The Court of Appeals

Summary

This consolidated case involved a double sale dispute over real property belonging to the estate of Pantaleon Jomoc. Maura So entered into an agreement to purchase the lot for P300,000.00 and made partial payments, but the deed was incomplete. Later, the Jomoc heirs sold the same property to spouses Lim, claiming So had backed out. The Supreme Court affirmed lower courts' findings that So did not abandon the purchase and that the contract was valid despite its incomplete form. Applying Article 1544 of the Civil Code, the Court ruled that the Lim spouses were not buyers in good faith as they purchased with knowledge of the prior sale and registered their deed after a notice of lis pendens was recorded. The decision established that mere registration without good faith does not confer superior right in double sale cases, and that partially executed contracts of sale remain enforceable even when incomplete in form if essential elements are present.