Coronel vs CA - Digest

Coronel v. CA

GR No. 103577 263 SCRA 15 October 7, 1996 Facts:

Romulo Coronel executed a document document entitled ³Receipt of Downpayment´ in favor of Ramona Patricia Alcaraz for P50,000 downpayment downpayment of the amount of  P1.24M as purchase pricefor an inherited house and lot, without reservation to withhold the transfer of such property untilfull payment. The purpose of  such downpayment downpayment was for the heirs to transfer the title to their name. Upon the registration of the property to name of the heirs, the Coronels sold the same property to Catalina B. Mabanag for P1.58M. The Coronels rescinded the contract with Alcaraz by depositing the downpayment amount in a bank account in favor of Alcaraz. Alcaraz filed acomplaint for specific performance, which the trial and the appellate court ruled in her favor. Issue:

Whet Whethe herr the the rece receip iptt of down downpa paym ymen ent´ t´ serv serves es a cont contra ract ct to sell sell or a conditional contractof sale. Held:

 The agreement agreement is a contract of sale as there was no express reservation reservation of  ownership or title to the subject parcel of land. Petitioners did not merely promise to sell the property to private respondent upon the fulfillment of the suspensive condition but on the contrary, havingalready agreed to sell the subject property, they undertook to have the certificate of title changedto their their name names s and and immed immedia iatel tely y there thereaft after, er, to execu execute te the the writt written en deed deed of  absolute sale. Thesuspensive condition was fulfilled on 6 February 1985 and thus, the conditional contract of sale between the parties became obligatory, the only act required for the consummation thereof beingthe delivery of the prop proper erty ty by mean means s of the the exec execut utio ion n of the the deed deed of abso absolu lute te sale sale in a publicinstrument, publicinstrument, which petitioners petitioners unequivocally unequivocally committed themselves themselves to do as evidenced by the³Receipt of Down Payment.´