- Petitioner
- Josefina Tayag
- Respondent
- Court of Appeals
- Citation
- G.R. No. 96053
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Melo, J.
- Decided
- March 3, 1993
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.
Intellegal Wiki · Key Holding
Affirmed with slight modification, holding that the vendors' acceptance of delayed installment payments waived their right to rescind under Article 1191, applying estoppel and Article 1235 on acceptance of irregular performance, and finding substantial compliance with a valid consignation under Article 1256 given conflicting claims among the heirs.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.