ANGELES VS.

CALASANZ
135 SCRA 323

FACTS:
On December 19, 1957, defendants-appellants
Ursula Torres Calasanz and plaintiffs-appellees
Buenaventura Angeles and Teofila Juani entered into a
contract to sell a piece of land located in Cainta, Rizal for
the amount of P3,920.00 plus 7% interest per annum. The
plaintiffs-appellees made a downpayment of P392.00 upon
the execution of the contract. They promised to pay the
balance in monthly installments of P41.20 until fully paid,
the installment being due and payable on the 19th day of
each month. The plaintiffs-appellees paid the monthly
installments until July 1966, when their aggregate
payment already amounted to P4,533.38.

On December 7, 1966, the defendants-appellants

wrote the plantiffs-appellees a letter requesting the
remittance of past due accounts. On January 28, 1967, the
defendants-appellants cancelled the said contract because
the plaintiffs failed to meet subsequent payments. The
plaintiffs’ letter with their plea for reconsideration of the
said cancellation was denied by the defendants.

The plaintiffs-appellees filed a case before the

Court of First Instance to compel the defendant to execute
in their favor the final deed of sale alleging inter alia that
after computing all subsequent payments for the land in
question, they found out that they have already paid the
total amount including interests, realty taxes and
incidental expenses. The defendants alleged in their
answer that the plaintiffs violated par. 6 of the contract to
sell when they failed and refused to pay and/or offer to pay
monthly installments corresponding to the month of
August, 1966 for more than 5 months, thereby
constraining the defendants to cancel the said contract.

The Court of First Instance rendered judgment in

favor of the plaintiffs, hence this appeal.

ISSUE:
Has the Contract to Sell been automatically and
validly cancelled by the defendants-appellants?

RULING:
No. While it is true that par.2 of the contract
obligated the plaintiffs-appellees to pay the defendants the
sum of P3,920 plus 7% interest per annum, it is likewise
true that under par 12 the seller is obligated to transfer the
title to the buyer upon payment of the said price.

The contract to sell, being a contract of adhesion,

must be construed against the party causing it. The
Supreme Court agree with the observation of the plaintiffsappellees
to the effect that the terms of a contract must be
interpreted against the party who drafted the same,
especially where such interpretation will help effect justice
to buyers who, after having invested a big amount of
money, are now sought to be deprived of the same thru the
prayed application of a contract clever in its phraseology,
condemnable in its lopsidedness and injurious in its effect
which, in essence, and its entirety is most unfair to the
buyers.

Thus, since the principal obligation under the

contract is only P3,920.00 and the plaintiffs-appellees
have already paid an aggregate amount of P4,533.38, the
courts should only order the payment of the few remaining
installments but not uphold the cancellation of the
contract. Upon payment of the balance of P671.67 without
any interest thereon, the defendant must immediately
execute the final deed of sale in favor of the plaintiffs and
execute the necessary transfer of documents, as provided
in par.12 of the contract.

Sagrada Orden vs. Nacoco 91 Phil. 503 (1952)

Nature: appeal from judgment of CFI of Manila

Facts and Background of the Case

- On Jan 4, 1942, during the Japanese occupation, Taiwan Tekkosho (Japanese corporation) acquired
the plaintiff’s property (land with warehouse in Pandacan, Manila) for Php140K
- On April 4, 1946, after the liberation, the US took control and custody of the aforementioned enemy’s
land under Sect 12 of the Trading with the Enemy Act
- In the same year, the Copra Export Management Company occupied the property under custodianship
agreement with the United States Alien Property Custodian
- In August 1946, when the Copra Export Management Co. vacated the property, the National Coconut
Corporation (NACOCO), the defendant, occupied it next
- Sagrada Orden (plaintiff) files claims on the property with the Court of First Instance of Manila and
against the Philippine Alien Property Administrator
- Plaintiff petitions that the sale of the property to Taiwan Tekkosho should be declared null and void as it
was executed under duress, that the interest of the Alien Property Custodian be cancelled, and that
NACOCO be given until February 28, 1949 to recover its equipment form the property and vacate the
premise
- The Republic of the Philippines is allowed to intervene
- CFI: the defendant (Philippine Alien Property Administrator) and the intervenor (RP) are released from
any liability but the plaintiff may reserve the right to recover from NACOCO reasonable rentals for the use
and occupation of the premises
- The sale of the property to the Taiwan Takkesho was declared void and the plaintiff was given the right
to recover Php3,000/month as reasonable rental from August 1946 (date when NACOCO occupied
property) to the date NACOCO vacates the premises
- the judgment is appealed to the SC

Legal Issues
1. WON the defendant is liable to pay rent for occupying the property in question

Judgment
1. The CFI’s decision that the defendant should pay rent from August 1946 to February 28, 1949 was
reversed, costs against the plaintiff

Ratio
Obligations can only arise from four sources: law, contracts or quasi-contracts, crime, or negligence (Art
1089, Spanish Civil Code).

There were no laws or an express agreement between the defendant or the Alien Property Custodian with
the plaintiff regarding payment of rent. The property was acquired by the Alien Property Administrator
through law (Trading with the Enemy Act) on the seizure of alien property and not as a successor to the
interests of the latter. There was no contract of rental b/w them and Taiwan Takkesho. NACOCO entered
possession of the property from the Alien Property Custodian without any expectation of liability for its
use. NACOCO did not commit any negligence or offense, and there was no contract, implied or
otherwise, entered into, that can be used as basis for claiming rent on the property before the plaintiff
obtained the judgment annulling the sale to Taiwan Takkesho. The plaintiff has no right to claim rent from
NACOCO.

Important Notes
Article 1157 of the New Civil Code states that there are 5 sources of obligations: laws, contracts, quasi-
contracts, felonies (acts or omissions punished by law), and quasi-delicts.