Case Digest on Obligations and Contracts: Statute of Frauds - San Miguel Properties, Inc. v. BF Homes, Inc. G.R. No. 169343
San Miguel Properties, Inc. v. BF Homes, Inc. G.R. No. 169343, [August 5, 2015] Facts: BF homes (BF) and San Miguel Properties Inc. (SMPI) entered three successive Deeds of Absolute Sale whereby the latter sold to the former a total of 130 Italia lots. SMPI completed payments of the 130 lots but only 110 of out of the 130 transfer of certificate of titles were delivered to SMPI. After demand which was unheeded, SMPI filed a complaint for specific performance with damages with the HLURB. In its answer, BF claims that Orendain was not authorized to enter into the Deed of Absolute Sale and that the Deeds of Absolute Sale were not notarized and were undated. Issue: Whether the Deeds of Absolute Sale are unenforceable for failure to comply with the Statute of Frauds Ruling: The Deeds are enforceable. The contracts of sale of the 130 Italia II lots between BF Homes and SMPI were reduced into writing into the three Deeds of Absolute Sale which were signed by the representatives of...