Short answer. A sale can also end through the same causes that extinguish any obligation generally, and through the specific grounds set out elsewhere in the Civil Code's Title on sales — redemption, whether conventional or legal, is only one item on a broader list.
What the law says
Sales are extinguished by the same causes as all other obligations, by those stated in the preceding articles of this Title, and by conventional or legal redemption.
Civil Code, Article 1600 — How Sales Are Extinguished. Read the full provision →
Article 1600 names three sources of extinguishment, not one
Article 1600 is written as a summary provision, and it points to three separate sources of grounds on which a sale can end. The first is the same causes as all other obligations — grounds that are not unique to sales at all, but apply to obligations in general under the Civil Code. The second is those stated in the preceding articles of this Title — meaning grounds set out specifically elsewhere within the Civil Code's provisions on sales. The third is conventional or legal redemption, which is only one of the three.
General causes that end obligations apply here too
Because a contract of sale is, at its core, a source of obligations between buyer and seller, the general causes that extinguish obligations of any kind also apply to end a sale. Article 1600 does not restate what those general causes are — it simply confirms that they are not excluded just because the obligation happens to arise from a sale. This is the broadest of the three categories the article identifies.
Sale-specific grounds found elsewhere in the same Title
The article also points to grounds stated in the preceding articles of this Title — provisions within the Civil Code's own chapter on sales that address situations particular to a sale contract, distinct from the general rules on obligations and distinct from redemption. Article 1600 does not repeat those grounds here; it simply confirms that they, too, are valid ways a sale can be brought to an end, in addition to the two other categories.
Redemption is one path among several
The article's mention of conventional or legal redemption confirms that redemption is a recognized way a sale ends, but Article 1600's own structure makes clear it is not the only one, or even the primary one — it is listed last, alongside two broader categories of causes. Anyone asking whether a sale can be undone or brought to an end without relying on redemption should look first to whether a general cause of extinguishment of obligations applies, or whether one of the sale-specific grounds found elsewhere in this Title fits the situation.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Emilla M. Uraca, et al. vs. Court of Appeals, et al, G.R. No. 115158, September 5, 1997 — read the decision on LawPhil →