**Ventura vs. Heirs of Spouses Endaya: A Case of Specific Performance and the Contingencies of Contract to Sell**
### Facts:
On June 29, 1981, Dolores Ventura entered into a contract to sell with Spouses Eustacio and Trinidad Endaya for two parcels of land in Parañaque City, Metro Manila, with an agreed purchase price of P347,760.00, to be paid with a downpayment and balance over 15 years plus interest. Dolores was permitted to take possession of the properties and construct a building thereon. Upon her death on April 10, 1992, her children (the Venturas) succeeded her interests and pursued the completion of the contract. They claimed to have made payments exceeding the agreed price, but upon their request for the execution of a deed of sale, the Endayas refused, leading to the Venturas filing a complaint for specific performance in the Regional Trial Court (RTC) of Parañaque City in 1996.
The Endayas argued that Dolores did not complete payments as agreed, and that they had renegotiated the terms of the contract several times, ultimately increasing the balance due which remained unpaid. The RTC ruled in favor of the Venturas, ordering the Endayas to execute a deed of sale. Dissatisfied, the Endayas appealed to the Court of Appeals (CA), which reversed the RTC’s decision, concluding the Venturas failed to comply with the terms of the contract to sell. The CA decision became final after procedural mishaps in serving the decision notice to the Venturas. In 2009, after being approached to vacate the property, the Venturas petitioned the Supreme Court to set aside the CA’s decision.
### Issues:
1. Whether the Venturas’ right to appeal before the Supreme Court should be upheld despite procedural lapses that led to the CA decision becoming final.
2. Whether the Endayas are obligated to execute a deed of sale in favor of the Venturas under the terms of the contract to sell.
### Court’s Decision:
The Supreme Court partly granted the petition, lifting the entry of judgment from the CA due to a procedural error in serving the decision notice to the Venturas. However, the Court affirmed the CA’s decision, holding that the Venturas failed to fulfill all the obligations under the contract to sell, including paying the real property taxes and interest on arrears, which prevented the obligation of the Endayas to execute the deed of sale from arising.
### Doctrine:
A contract to sell is contingent upon the buyer’s fulfillment of the conditions agreed upon, such as full payment of the purchase price. Failure to meet these conditions prevents the obligation to transfer ownership from arising, distinguishing it from a conditional contract of sale where the fulfillment of conditions automatically transfers ownership.
### Class Notes:
– **Contract to Sell vs. Conditional Sale**: The obligation of the seller to transfer ownership in a contract to sell is contingent upon the fulfillment of agreed conditions by the buyer, while in a conditional sale, the fulfillment of conditions automatically transfers ownership.
– **Obligations in a Contract to Sell**: Buyers must fulfill all conditions stated in the contract, including payment of the purchase price, interest, arrears, and other charges like real property taxes, to obligate the seller to execute a deed of sale.
– **Effects of Non-Compliance**: Failure to comply with all obligations under a contract to sell precludes the buyer’s right to compel the seller to execute a deed of sale and transfer ownership.
– **Appeals in Civil Procedure**: Procedural mishaps in serving decision notices can affect the finality of decisions and the right to appeal, underlining the importance of correct procedural service for due process.
### Historical Background:
This case illustrates the procedural intricacies and substantive legal principles underlying contracts to sell in the Philippines. It underscores the pivotal role of compliance with contract terms for transferring real property ownership and the procedural safeguards ensuring parties’ rights to appeal court decisions.
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