Heirs of San Juan Andres vs.

Rodriguez
G.R. 135634 - 332 SCRA 769

Facts:
Juan San Andres sold a portion of his land to respondent Vicente Rodriguez evidenced by a Deed of
Sale. Upon the death of Juan, Ramon San Andres was appointed judicial administrator of his estate.
Ramon engaged the serviced of geodetic engineers to survey the lot. From such survey, thtey
discovered that the respondent had enlarged the area which he purchased from the late Juan.
Ramon then send a letter demanding the respondent to vacate the portion allegedly encroached by
him.

However, respondent refused to do so claiming that he purchased the same from the late Juan with
both parties treating the two lots as one who parcel of land. Respondent further alleged that the full
payment of the additional lot would be effected within five (5) years from the execution of the deed of
sale after a survey is conducted over said property. Respondent attached to his answer a receipt
signed by the late Juan as proof of the purchase.

Respondent thereafter deposited in the court the balance of the purchase price. While the case is
pending, Ramon died and was replaced by son Ricardo. Vicente also died and was substituted by his
heirs. The trial court rendered judgement in faovr of the petitioner and ruled that there was no
contract of sale because there is no valid object because there is no sufficient indication. Respondent
Court of Appeals reversed the decision rendered by the Trial Court.

Issues:
Whether the Court erred in holding that there is a valid contract of sale?

Whether the Court erred in holding that the consignation is valid?

Whether the amount of consignation is untenable?

Whether the respondent is barred by prescription and laches from enforcing the contract?

Rulings:
1. There is a valid Contract of Sale because all the essential elements are present. In herein
case, petitioner’s contention that there is no determinate object is without merit. The receipt
described the lot as “previously paid lot”. Since the lot subsequently sold to respondent is said
to adjoin the “previously paid lot” on three sides thereof, the subject lot is capable of being
determined without the need of any new contract.

The contract of Sale can be gainsaid to be absolute because there is no reservation of

ownership. The stipulation “payment of full consideration based on a survey shall be due and
payable in five (5) years from the execution of deed of sale” is not a condition which affects the
efficacy of the contract. It merely provides for the manner of computation of payment.

2. Consignation is proper only in cases where an existing obligation is due. In herein case since
there is no deed of sale yet thus the period when the purchase price should be paid has not
commenced yet which makes it not yet due and demandable. The court is not erroneous
because it thereafter ordered the execution of deed and the acceptance of the deposit.

3. The amount is based on the agreement which is the law between the parties. Thus, it is
binding and the court can only give force and effect to the intentions of the parties.

4. Since there was no Deed of Sale yet and the respondent wants to pay the purchase price, he
deemed it proper to deposit it in the Court. Thus, Prescription does not apply.