Seller's Right to Withhold Deed Until Full Payment

A property owner, having entered into a contract to sell a parcel of land, subsequently executed a formal deed of sale before a notary but only delivered the signed deed to the buyer after the buyer had paid a portion of the price. The buyer subsequently sued for damages, alleging the delay in delivery caused financial prejudice due to market fluctuations. The court upheld the lower court's decision to reject the claim, reasoning that the contractual obligation to deliver the deed only arose upon full payment of the price, and therefore, the seller was not in breach of contract by withholding the deed until the payment obligation was satisfied.