Practice question
A developer accepts several payments under a reservation arrangement but never supplies the promised contract to sell. It argues that the number of receipts alone proves a perfected installment sale and compels a 50% refund limit. What matters under Empire East?
- The actual agreement and whether the transaction progressed beyond reservation
- Receipt count alone conclusively creates a sale
- Only the developer’s accounting label matters
- Every reservation payment automatically transfers ownership
- All reservation disputes are governed exclusively by Section 3
Legal references
- Empire East Land Holdings, Inc. v. Bautista, G.R. No.272556, February 3, 2026, MAIN decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70374
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