GR 107624; (January, 1997) (Digest)
G.R. No. 107624 January 28, 1997
GAMALIEL C. VILLANUEVA and IRENE C. VILLANUEVA, petitioners, vs. COURT OF APPEALS, SPOUSES JOSE and LEONILA DELA CRUZ, and SPOUSES GUIDO and FELICITAS PILE, respondents.
FACTS
Petitioners, tenants in a property owned by respondents Spouses Dela Cruz, expressed interest in purchasing the land and apartment building in 1986. Respondent Jose Dela Cruz requested and received P10,000 from petitioner Irene Villanueva to pay for delinquent realty taxes, with an understanding it would form part of a total sale price of P550,000. Later, the parties agreed to subdivide the property, with petitioners to purchase one-half for P265,000, crediting the P10,000 advance. However, in March 1987, the Dela Cruz spouses executed a Deed of Assignment over that same half in favor of respondent Spouses Pile to settle a debt, and a new title was issued to them.
Petitioners filed an action for specific performance, claiming a perfected contract of sale existed. The trial court dismissed the complaint but ordered a refund of the P10,000. The Court of Appeals affirmed, leading to this petition.
ISSUE
Was there a perfected contract of sale between petitioners and respondents Spouses Dela Cruz?
RULING
No. The Supreme Court affirmed the lower courts, holding no contract of sale was perfected. For a contract of sale to be perfected under Article 1475 of the Civil Code, there must be a meeting of the minds upon the thing which is the object of the contract and upon the price. The Court found this essential element lacking. The evidence, including testimony from Jose Dela Cruz, established that while there were ongoing negotiations, no final agreement on the terms—specifically the manner and schedule of payment for the balance of the purchase price—was ever reached. The P10,000 was deemed a mere advance for tax payments, not earnest money signifying perfection. The subsequent sale to the Spouses Pile was therefore valid. The Court emphasized that the findings of fact of the Court of Appeals are binding unless exceptions exist, none of which were present here. The claim of a partly executed contract was rejected, as the advance was not intended as partial payment constitutive of perfection.