Case Digest (G.R. No. 4710)
Facts:
The case of Leon Agcaoili vs. Benito Acasio was decided by the Supreme Court of the Philippines on January 26, 1909. The plaintiff, Leon Agcaoili, initiated the action in the Court of First Instance of Ilocos Norte to reclaim possession of three tracts of land that were acknowledged to be in the possession of the defendant, Benito Acasio. The dispute traces back to January 16, 1884, when Maria Acasio, the aunt of the defendant, owned the property in question. On that date, she executed a document transferring the land to Agcaoili, allowing him to cultivate it and collect rents until she repaid a debt of 20 pesos. However, Maria Acasio never settled this debt. On April 1, 1891, while still in possession of the land, Agcaoili transferred it to Benito Acasio, noting that the transfer was due to Acasio's payment of the aforementioned debt. Agcaoili claimed that their agreement allowed him to redeem the land by returning the 20 pesos. He testified that he repaid this amount ...
Case Digest (G.R. No. 4710)
Facts:
Ownership and Initial Agreement (1884):
- Maria Acasio, the aunt of the defendant Benito Acasio, owned three tracts of land.
- On January 16, 1884, Maria Acasio executed a document in favor of the plaintiff, Leon Agcaoili, stating that she delivered the land to him to work and take its rents and profits until she repaid a debt of 20 pesos.
Transfer to Defendant (1891):
- On April 1, 1891, the plaintiff delivered the land to the defendant, Benito Acasio, and wrote a note on the original document stating that the defendant had paid the 20 pesos.
- The plaintiff testified that the agreement with the defendant included a right to redeem the land by repaying the 20 pesos.
Redemption and Re-Possession (1901):
- On May 2, 1901, the plaintiff claimed to have repaid the 20 pesos to the defendant and regained possession of the land.
- The plaintiff remained in possession and cultivated the land until 1906, paying taxes during this period.
Defendant's Re-Entry (1906):
- In 1906, the defendant re-entered the land and took possession, leading the plaintiff to file a lawsuit to recover the land.
Evidence Presented:
- The plaintiff presented three witnesses who testified that in 1905, the defendant executed a counter-receipt acknowledging the repayment of 20 pesos and the plaintiff's right to the land.
- The defendant denied executing the counter-receipt but provided no substantial evidence to contradict the plaintiff's claims.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Redemption and Resale:
- The Court found that the plaintiff had validly redeemed the land by repaying the 20 pesos in 1901, and the defendant had accepted the repayment, thereby transferring ownership back to the plaintiff.
- Even if the initial transaction in 1891 was a sale with a right to repurchase, the defendant's subsequent resale of the land to the plaintiff in 1901 extinguished any prior claims.
Burden of Proof:
- The plaintiff's testimony and the corroborating evidence of the counter-receipt and witnesses sufficiently established his claim.
- The defendant failed to provide credible evidence to contradict the plaintiff's assertions.
Right to Deal with Property:
- The defendant, as the owner of the land in 1901, had the legal right to resell it to the plaintiff on mutually agreed terms.
- The Court emphasized that the parties' agreement in 1901 was valid and binding, regardless of the prior transaction.