Romulo Coronel et al vs Court of Appeals

GR no. 103577
October 7, 1996

Facts:
1) The Coronels, sold a parcel of land to Ramona Alcatraz in January 1985 in the sum of
1,240,000.
2) They executed a Receipt of Downpayment, whereby Ramona gave an advance
payment of Php 50,000. Along with the receipt is an stipulation that the parcel of land
and its improvements will have to first be transferred to the name of the heirs of
Coronel. After such, the title will be transferred to Ramona and she will then pay the
outstanding balance of Php 1,190,000.
3) On February 6, 1985, the title was transferred in the name of the Coronels.
4) On February 18, 1985, the Coronels sold the property to Catalina Mabanag.
5) The Coronels rescinded their contract with Ramona.
6) The mother of Ramona filed a case for specific performance against the Coronels and
caused the annotation of a notice of lis pendens.
7) Catalina also caused the annotation of an adverse claim in the registry of Deeds.
8) The Coronels executed a Deed of Absolute Sale in favor of Catalina.
9) A new title was issued to Catalina.
10) The RTC ruled in favor of Ramona, ordering the Coronels to execute a Deed of Absolute
Sale . CA affirmed the same.

Issue:
Was there a valid contract of sale with Ramona?

Held:
No. The defense of the Coronels that there was only a Contract to Sell and such did not ripen
into a contract of absolute sale is not meritorious because at the time the document was
executed, the real intention of the Coronel was to sell their property. There is no contract to
sell. There was a contract to sell subject to the suspensive condition that the Coronels cause the
transfer of the title to their name.

Catalina cannot be said to be a buyer in good faith because Ramona caused an annotation on
the title. Catalina even caused the annotation in the Registry of Deeds. She was aware of the
defect when the Deed of Absolute Sale was executed.