09/03/2026
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In the case of Ocampo v. Batara-Sapad (2025), the Supreme Court ruled that an oral sale of land may still be valid and binding when it has been partially or fully executed. Acts such as the buyerβs taking possession of the property, introducing improvements, and making payments may serve as indicators that the contract of sale had already been carried out.
In this case, the buyer paid an initial amount to the owner and was allowed to take possession of the land. After the sellerβs death, however, the buyer continued paying installments to the sellerβs brother, who had no authority to receive payment on behalf of the heirs.
The Court held that while the verbal sale remained enforceable due to its partial ex*****on, the buyerβs payments to the unauthorized person did not extinguish his obligation. Thus, the buyer was ordered to pay the remaining balance of the purchase price to the heirs, after which the heirs must execute the proper deed of sale in his favor.
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