G.R. No. L-7895, December 29, 1913
VICTORINO DEL CASTILLO, plaintiff-appellee, vs. PABLO ESCARELLA, defendant-appellant.

FACTS:
Victorino del Castillo filed an action for ejectment and specific performance against Pablo Escarella. Del Castillo alleged that in April 1901, he purchased two parcels of abaca land from Escarella for P1,200, payable in installments. He took possession, improved the land, and had paid P1,150, leaving a balance of P50. He demanded that Escarella execute a formal deed of sale, but Escarella refused and, on July 1, 1911, usurped the property. Escarella denied the sale, claiming del Castillo was merely a caretaker or tenant, and that the payments received were from crop shares or a reimbursement of a deposit. The trial court ruled in favor of del Castillo, ordering Escarella to restore possession, execute a deed of conveyance, and pay for the 1911 crop, after deducting the P50 balance. Escarella appealed.

ISSUE:
Whether a valid contract of sale existed between the parties, thereby entitling del Castillo to recover possession and compel the execution of a formal deed of conveyance.

RULING:
Yes. The Supreme Court affirmed the trial court’s judgment. The Court found the evidence, particularly three letters (Exhibits A, B, and C) written and signed by Escarella, conclusively proved the existence of a verbal contract of sale. In these letters, Escarella referred to the “balance” for the land purchased by del Castillo and requested payments. The contract, though verbal, was perfectly valid. The sale occurred in April 1901, prior to the enactment of the Code of Civil Procedure, and was governed by the Civil Code. Under Articles 1278 and 1280 of the Civil Code, a verbal contract for the sale of real estate is valid and binding if the essential conditions for its validity are present. The requirement for a written instrument is not for validity but is a coercive means for either party to compel the other to reduce the agreement to the proper form. Therefore, del Castillo, as the rightful owner unlawfully deprived of possession, was entitled to recover the land, pay the remaining balance, and compel Escarella to execute the corresponding deed of sale. Escarella was also liable for the value of the crops he gathered from the land.