Josefina Tayag v. Court of Appeals

Summary

This case involves a land sale contract dispute where the heirs of deceased vendor Juan Galicia Sr. claimed breach by vendee Albrigido Leyva for incomplete installment payments. The Supreme Court affirmed lower courts' findings that the vendors waived their right to rescind by accepting delayed payments over several years without protest. Applying Civil Code provisions on estoppel (Article 1235) and constructive fulfillment (Article 1186), the Court held that substantial compliance occurred through the vendee's various payments totaling over P32,000, with consignation of the final amount. The decision establishes that acceptance of delayed payments in installment contracts constitutes waiver of the right to rescind, and that substantial performance suffices when vendors have acquiesced to irregular payment schedules. The case demonstrates the application of equitable principles in contract enforcement, protecting parties who have substantially performed despite technical breaches.