Can a Sales Agent’s Promise to Issue a Contract to Sell After Payment of a Reservation Fee Constitute an “Advertisement” Under PD 957, and Does the Developer’s Failure to Honor the Promise Entitle the Buyer to a Refund?
The Supreme Court, in Empire East Land Holdings, Inc. v. John Edrem Bautista, G.R. No. 272556, February 3, 2026, clarified that a sales agent’s promise to issue a Contract to Sell after payment of a reservation fee is not an “advertisement” under Section 19 of Presidential Decree No. 957 (PD 957). However, the Court held […]






