G.R. No.

L-42283 March 18, 1985

BUENAVENTURA ANGELES, ET AL., plaintiffs-appellees,
vs.
URSULA TORRES CALASANZ, ET AL., defendants-appellants
Facts:
• On December 19, 1957, Ursula Torres Calasanz and Tomas Calasanz
(defendants-appellants) entered into a contract to sell a piece of land in Cainta,
Rizal, with Buenaventura Angeles and Teofila Juani (plaintiffs-appellees) for the
amount of P3,920.00 plus 7% interest per annum.
• The plaintiffs made a downpayment of P392.00 and agreed to pay the balance in
monthly installments.
• The plaintiffs paid the monthly installments until July 1966, amounting to
P4,533.38.
• On December 7, 1966, the defendants wrote a letter requesting past-due
payments.
• On January 28, 1967, the defendants canceled the contract due to the plaintiffs'
failure to make subsequent payments.
• The plaintiffs filed a case to compel the defendants to execute a final deed of
sale, alleging that they had paid the total amount due, including interests, realty
taxes, and expenses for land registration.
Issues:
• Whether the contract to sell was validly canceled by the defendants-appellants.
• Whether the defendants should be ordered to execute a final deed of sale.
• Whether the defendants should pay attorney's fees.
Ruling: The main issue is whether the contract to sell was validly canceled by the
defendants-appellants. The contract contained a provision allowing the sellers to cancel
the contract if the buyer failed to make payments for a specified period. However, the
court found that the breach by the plaintiffs was slight and casual, given that they had
already paid a substantial portion of the obligation and that the total monthly
installments had exceeded the principal amount. The court held that the cancellation by
the defendants was unjust and would result in unjust enrichment.
The court also considered the contract a contract of adhesion, as it had been drafted by
the defendants, and interpreted it against the defendants, ordering the plaintiffs to pay
the remaining balance without interest and the defendants to execute the final deed of
sale.
In conclusion, the court ruled against the defendants on all three issues:
• The contract was not validly canceled.
• The defendants were ordered to execute the final deed of sale.
• The defendants were ordered to pay attorney's fees.
The judgment was affirmed with the modification of the interest on the remaining
balance and the award of attorney's fees.