Case Digest (G.R. No. L-3227)
Facts:
On March 13, 1905, Pedro Alcantara (plaintiff and appellee) filed a complaint in the Court of First Instance of La Laguna against Ambrosio Alinea and Eudosia Belarmino (defendants and appellants). The complaint sought a judgment ordering the defendants to deliver a house and lot to the plaintiff and to pay him 8 pesos per month as rent starting from February 1905, along with the costs of the action. The plaintiff alleged that on February 29, 1904, the defendants borrowed 480 pesos from him, with the agreement that if the amount was not repaid by January 1905, the house and lot owned by the defendants in San Pablo, La Laguna, would be considered sold to the plaintiff for that amount. The defendants failed to repay the loan by the due date and refused to deliver the property, which led to the plaintiff's claim of loss of rental income. The defendants responded by denying the allegations, claiming the principal amount borrowed was only 200 pesos, with the remaining 280 pesos...
Case Digest (G.R. No. L-3227)
Facts:
Loan Agreement and Promise of Sale
- On February 29, 1904, defendants Ambrosio Alinea and Eudosia Belarmino borrowed 480 pesos from plaintiff Pedro Alcantara.
- The agreement stipulated that if the loan was not repaid by January 1905, the defendants' house and lot in San Pablo, La Laguna, would be considered absolutely sold to the plaintiff for the same amount.
- The property was described in detail in the complaint, and the house was constructed of strong materials.
Failure to Repay and Refusal to Deliver Property
- The defendants failed to repay the loan by the agreed-upon date.
- Despite the expiration of the repayment period, the defendants refused to deliver the property to the plaintiff.
- The plaintiff sought delivery of the property and claimed 8 pesos per month as rent from February 1905, along with costs of the action.
Defendants' Defense
- The defendants denied most allegations in the complaint, except for admitting the loan.
- They claimed the principal amount borrowed was only 200 pesos, with 280 pesos as interest, but the total was recorded as 480 pesos in the document.
- They alleged they had offered to repay the 480 pesos, but the plaintiff refused to accept it.
Trial Court Decision
- The trial court ruled in favor of the plaintiff, ordering the defendants to deliver the house and lot to the plaintiff and to pay the costs of the action.
- The court did not award damages due to a lack of proof.
- The defendants appealed the decision, arguing that the findings were contrary to law.
Issue:
Validity of the Contract
- Whether the contract, which combined a loan agreement with a promise of sale, was valid under the Civil Code.
Nature of the Agreement
- Whether the agreement constituted a mortgage, pledge, or antichresis, or if it was a valid promise of sale.
Enforceability of the Promise of Sale
- Whether the promise of sale could be enforced given the defendants' failure to repay the loan.
Defendants' Offer of Payment
- Whether the defendants' offer to repay the loan absolved them of their obligation to transfer the property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Dissent
Justice Willard dissented, arguing that the contract violated fundamental principles of Spanish law. He contended that the agreement deprived the debtor of all interest in the property without the right to redeem or have the property sold to pay the debt, which was prohibited under Articles 1859, 1872, and 1884 of the Civil Code.