10/05/2026
"Under Articles 1477 and 1496 of the Civil Code, ownership of the thing sold is vested in the buyer upon delivery. Article 1582 of the same Code obligates the buyer to accept delivery and pay the price of the thing sold. Benedicto and Daisy's testimonies, coupled with the undisputed fact of their possession, clearly show that the disputed lot had been delivered to them. Like Almirol and Heirs of Alido, the case at bar involves an executed unwritten sale of real property where the seller delivered the muniments of title and possession of the property to the buyer upon payment of the purchase price. Still akin to Almirol, delivery of title and possession was made after partial payment of the purchase price, with the seller passing away thereafter. However, in Almirol, it was proven that the buyer eventually paid the full price to a person authorized to receive payment, after the seller's demise. Here, when Marcos passed away, Benedicto paid the balance of the purchase price to Marcelo because the latter was Noblesa's de facto guardian; however, there is no other evidence or circumstance on record, written or otherwise, to show Marcelo's express or implied authority to receive the installment payments on behalf of Marcos or his heirs....Under Article 1497 of the Civil Code, the object of a sale contract is deemed delivered when it is placed in the control and possession of the vendee, in this case, the year 1982. Article 1589 of the same Code further provides that the buyer shall owe interest for the period between delivery of the thing and payment of the purchase price if the thing sold and delivered produced fruits or income. The law imposes interest on the unpaid purchase price to prevent unjust enrichment of buyers who enjoy the fruits of the thing sold without fully complying with their obligation to pay the purchase price.Here, Benedicto and Daisy testified that upon taking possession, they cleared the lot and planted crops thereon. They further claim having "receiv[ed] the agricultural fruits thereof for forty (40) years or more uninterrupt[ed]ly." Applying guideline B.1. of Our ruling in Lara's Gifts & Decors, Inc. v. Midtown Industrial Sales, Inc., Benedicto and Daisy must pay the balance of the purchase price, in the amount of PHP37,000.00, with interest at the legal rate, reckoned from the end of the year when they took possession of the lot, in accordance with Article 1589 (2) of the Civil Code, until full payment of the purchase price. The interest due on the unpaid balance shall also earn interest at the legal rate from the same date until full payment, as the judgment award is considered a forbearance of credit during such time. Upon full payment of the purchase price, Noblesa and Ernesto must fully implement the contract entered into by their father by executing a deed of sale in favor of Benedicto." (Ocampo v. Batara-Sapad, G.R. No. 256343, (02 April 2025))
