Paredes v Espino – 1968

FACTS: Paredes filed a complaint in order to compel Espino to ISSUE: W/N the contract is unenforceable
execute a deed of sale of a parcel of land in Puerto Princessa &
RULING: NO, The court ruled it was already sufficient that the
pay damages.
contract was backed by a letter and telegram being a
 A deal has already been set between Paredes and sufficient memorandum aka a “written agreement” exist
Espino, that the Espino would sell his property to between the contracting parties.
Paredes.
DOCTRINE: In contracts involving selling real property,
the contract must be embodied in a written form for it to be
 The deal has been already closed by a letter and
enforceable under the statute of frauds.
telegram- only awaiting actual execution of the deed of
sale and payment of the price.

 Sale was deferred until the arrival of Espino

 Once Espino had arrived, he still refused to execute the

deed of sale, despite Paredes willing and had money to
pay for such property.

 Which resulted Paredes to suffer loss from the expected

profits from property that he was about to resell.
Experiencing sleepless nights from this circumstance

 Espino’s defense- no cause of action Paredes’ claim is

unenforceable under that statue of frauds. Espino’s
contention is that the authenticity of the letter was not
established in the deal.