- Petitioner
- Jaime G. Ong
- Respondent
- The Honorable Court of Appeals
- Citation
- G.R. No. 97347
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- July 6, 1999
Summary
This case involves the rescission of an Agreement of Purchase and Sale between Jaime Ong (buyer) and the Robles spouses (sellers) for agricultural land worth P2,000,000. Ong failed to complete payment of the purchase price - he underpaid the bank loan settlement and his four quarterly installment checks were dishonored. The sellers sued for rescission after demanding return of the properties. The Supreme Court affirmed the lower courts' decisions setting aside the contract, clarifying that it was a 'contract to sell' where payment is a suspensive condition. The Court rejected Ong's claims of novation, finding no clear intent to modify the original agreement. The decision established important distinctions between contracts of sale versus contracts to sell, and requirements for proving novation in contractual relationships.