Case Digest (G.R. No. 155018)
Facts:
The case involves Philadelphia Agan as the petitioner and the heirs of Spouses Andres Nueva and Diosdada Nueva, represented by Lou Nueva and Al Nueva, as the respondents. The events leading to the case began on April 13, 1988, when Diosdada Nueva, with the consent of her husband Andres, sold a parcel of land measuring 2,033 square meters located in Kauswagan, Cagayan de Oro City, to Philadelphia Agan for P21,000. This transaction was formalized through a public instrument titled "Deed of Sale under a Pacto de Retro," which granted the Nuevas the right to repurchase the property within six months for the same amount. However, the Nuevas failed to exercise this right within the stipulated period. Following Diosdada's death on July 5, 1991, the property was extrajudicially partitioned, and Andres sold his interest in the land to his children, Ann and Lou. Due to a fire that destroyed the original title, a new title was reconstituted and registered under TCT No. 634...
Case Digest (G.R. No. 155018)
Facts:
- Transaction Details: On April 13, 1988, Diosdada Nueva, with marital consent, sold a parcel of land under a pacto de retro to Philadelphia Agan for P21,000. The property, covered by TCT No. 25370, was registered in the name of Spouses Andres and Diosdada Nueva. The agreement allowed the Nuevas to repurchase the property within six months for the same amount.
- Failure to Repurchase: The Nuevas failed to repurchase the property within the stipulated six-month period.
- Partition and Reconstitution of Title: After Diosdada Nueva's death on July 5, 1991, the property was extrajudicially partitioned. Andres Nueva sold his interest to his children Ann and Lou. The title, lost in a fire, was reconstituted and transferred to Ann and Lou under TCT No. 63403.
- Consolidation of Ownership: On June 19, 1992, Agan filed a petition for consolidation of ownership. The Nuevas argued that the pacto de retro sale was an equitable mortgage, citing the property's fair market value of P81,320. The RTC ruled in favor of Agan but granted the Nuevas 30 days to redeem the property.
- Redemption Attempt: The Nuevas offered to redeem the property for P52,080, but Agan refused, leading to consignation of the amount in court.
- Petition for Relief: Agan filed a petition for relief, arguing that the 30-day redemption period was surplusage. The RTC amended its decision by deleting the redemption period. The Nuevas filed a motion for reconsideration, which was denied.
- Court of Appeals Decision: The Court of Appeals reversed the RTC's order, ruling that Agan's failure to appeal the decision rendered it final and executory. The appellate court held that the mistake alleged by Agan was a mistake of law, not fact, and thus not a valid ground for relief.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Mistake of Law vs. Mistake of Fact: Relief from judgment under Rule 38 is available only for mistakes of fact, not law. Agan's belief that the redemption period was surplusage was a mistake of law, which does not justify relief.
- Finality of Judgment: Agan's failure to appeal the RTC decision within the reglementary period rendered it final and executory. She cannot now seek relief based on her erroneous interpretation of the law.
- Equitable Mortgage Defense: The Nuevas' defense that the pacto de retro sale was an equitable mortgage was made in good faith, and the RTC correctly applied Article 1606 of the Civil Code in granting them 30 days to redeem the property.
- Jurisdiction of the RTC: The RTC had jurisdiction to allow the Nuevas to repurchase the property. Any error in the decision would be an error of judgment, not jurisdiction.
- Legislative Intent of Article 1606: Article 1606 is intended to protect vendors in pacto de retro sales, especially when there is a good faith belief that the transaction was an equitable mortgage. The RTC's decision was consistent with this legislative intent.