Facts:

On May 27, 1907, Juana Cantos, represented by her husband Jose Alano, filed an amended complaint against Jose Babasa. The complaint alleged that Juana's legitimate father had incurred a debt of P1,030 to Fulgencio Babasa and Maria Cantos, who were the parents of the defendant, Jose Babasa. To secure this debt, Juana's father pledged a parcel of land located in the barrio of Pinamukan, Batangas, with the condition that the creditors would enjoy the usufruct of the land from the date of the contract, which was July 18, 1883. The agreement stipulated that the debtor could redeem the land at any time after seven years by paying off the debt. Following the death of the creditors, Juana's husband sought to redeem the land from Jose Babasa, who was then in possession of the usufruct. Initially, Babasa agreed to allow the redemption but later proposed to sell the land for an increased price of P1,370, which Juana refused. Consequently, Babasa denied her right to redeem th...

Facts:

Background and Transaction Details

• On May 27, 1907, Juana Cantos, assisted by her husband Jose Alano, filed an amended complaint alleging that her legitimate father had incurred a debt of P1,030 in favor of Fulgencio Babasa and Maria Cantos.
• To guarantee the debt, a parcel of land located in the barrio of Pinamukan, Batangas, was pledged. The contract providing for this pledge was entered into on July 18, 1883.
• The agreement granted the creditors the usufruct of the land from the date of the contract, with the understanding that the debtor could redeem the property at any time after a seven-year period by paying the debt.
• After the death of the creditors, the plaintiff—acting personally and through intermediaries—attempted to redeem the land, but the defendant, Jose Babasa, first proposed a definitive purchase at an increased price (P1,370) and then ultimately refused to allow redemption when the plaintiff declined to pay the higher amount.

Defendant’s Position and Counterclaim

• The defendant denied the allegations entirely, asserting that the land had been sold with a right of repurchase to Fulgencio Babasa on July 18, 1883, for P1,000, of which 300 pesos were contributed by Jose Babasa, the defendant’s father.
• It was stipulated in the contract that the sellers would have the right to redeem the property within a seven-year period that commenced from the contract date.
• Since the sellers (the parents of the plaintiff) did not act within the stipulated period, the defendant contended that their right to repurchase had lapsed.

Evidence and Documentary Basis

• Both parties presented evidence, including witness testimonies and documents to support their claims.
• A signed contract, appearing in a document written in Tagalog and translated into Spanish, was produced. This document outlined the sale with the right of repurchase and detailed the terms, boundaries of the parcel, and the agreement for possession for seven years under usufruct.
• The authenticity of the contract was confirmed by its admission as evidence by the plaintiff when presented by the defendant.

Legal and Temporal Context

• The contract was characterized as a sale with a right of repurchase rather than a contract of loan with mortgage, falling under the provisions of article 1507 et seq. of the Civil Code.
• The contract was held to be valid, perfect, and efficient because it satisfied the requisites of article 1261 of the Civil Code, notwithstanding its preparation as a private document under article 1278.
• The sellers’ right to repurchase was meant to become operative after the lapse of the seven-year usufruct period, specifically commencing on July 19, 1890.
• Subsequent to the effective date of the Civil Code (December 8, 1889), the exercise of the right of repurchase was further regulated by a four-year period fixed by article 1508.

Prescription and Statutory Framework

• The core issue revolved around whether the plaintiff’s right to repurchase could be compelled after the expiration of the prescribed redemption period as enumerated in article 1508.
• Prescription of the right to repurchase was also discussed under article 1939 and other relevant provisions (articles 1932 and 1936) regarding the timely exercise of contractual rights and the effects of prescription on all classes of persons.
• It was argued that even if the right to repurchase were considered to have commenced from the date of the contract or the day after, the four-year period had expired by the time of the filing of the suit in 1907.

Issue:

Determination of the Proper Redemption Period

• Whether the right of repurchase as stipulated in the contract should be measured from the date of the contract (July 18, 1883) or from the date after the usufruct period (July 19, 1890).
• The implication of these differing starting points on the calculation of the prescribed period for redemption, particularly under article 1508 of the Civil Code.

Application of the Prescription Rules

• Whether the four-year period (as prescribed by article 1508) for the exercise of the right of repurchase had indeed expired by the time the complaint was filed in 1907.
• How the provisions of article 1939, governing prescription of actions that began under prior law, apply to this case.

The Legal Effect of Expiration of the Redemption Right

• Whether any exception, including the alleged minority of the plaintiff, could extend or suspend the statutory deadline for repurchase.
• The effect of the lapse of the statutory period on the enforceability of the contract and the plaintiff’s claim for redemption.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)