CONGREGATION OF THE RELIGIOUS V. OROLA (CIVIL)

As uniformly found by the lower courts, we likewise find that there was a perfected contract of sale between the parties. A CONTRACT OF SALE carries the correlative duty of the seller to deliver the property and the obligation of the buyer to pay the agreed price. As there was already a binding contract of sale between the parties, RVM had the corresponding obligation to pay the remaining balance of the purchase price upon the issuance of the title in the name of respondents. The supposed 2-year period within which to pay the balance did not affect the nature of the agreement as a perfected contract of sale.

The absence of fraud and bad faith by RVM notwithstanding, it is liable to respondents for interest. RVM breached the contract of sale by refusing to pay the balance of the purchase price despite the transfer to respondents' names of the title to the property. The 2-year period RVM relies on had long passed and expired, yet, it still failed to pay. It did not even attempt to pay respondents the balance of the purchase price after the case was filed, to amicably end this litigation.

Lastly, to obviate confusion, the clear language of Article 1191 mandates that damages shall be awarded in either case of fulfillment or rescission of the obligation. In this regard, Article 2210 of the Civil Code is explicit that "interest may, in the discretion of the court, be allowed upon damages awarded for breach of contract." The ineluctable conclusion is that the CA correctly imposed interest on the remaining balance of the purchase price to cover the damages caused the respondents by RVM's breach.