Case Digest (G.R. No. L-3227)
Facts:
In Pedro Alcantara vs. Ambrosio Alinea et al., plaintiff‐appellee Pedro Alcantara filed on March 13, 1905, in the Court of First Instance of La Laguna a complaint against defendants‐appellants Ambrosio Alinea and Eudosia Belarmino. He alleged that on February 29, 1904, the defendants borrowed ₱480 from him, payable in January 1905, with a stipulation that failure to repay would render their strong‐material house and lot in San Pablo, La Laguna, absolutely sold to him for that sum. Upon expiration of the term and nonpayment, defendants allegedly refused to deliver possession, thereby depriving Alcantara of monthly rental income of ₱8 beginning February 1905. Defendants demurred, admitted only the indebtedness, claimed ₱200 principal plus ₱280 interest totaling ₱480, and asserted they tendered the full ₱480 but Alcantara refused it. At trial the lower court heard testimony, admitted the signed instrument, and on November 27, 1905, ordered delivery of the property and costs againstCase Digest (G.R. No. L-3227)
Facts:
- Transaction and complaint
- On February 29, 1904, defendants Ambrosio Alinea and Eudosia Belarmino borrowed ₱480 from plaintiff Pedro Alcantara, payable January 1905, with stipulation that nonpayment would convert the loan into an absolute sale of their house and lot in San Pablo, La Laguna.
- Plaintiff filed suit March 13, 1905, in the Court of First Instance of La Laguna, praying (a) delivery of the property; (b) rent of ₱8 per month from February 1905; and (c) costs.
- Defendants’ answer and trial court proceedings
- Defendants denied most allegations, contending the ₱480 comprised ₱200 principal and ₱280 interest, and tendered ₱480, which plaintiff refused. They sought costs.
- After evidence and document admission, on November 27, 1905, the trial court ordered delivery of the house and lot and assessed costs, making no finding on rent or damages. A motion for new trial was denied.
Issues:
- Contract validity
- Whether the combined loan and conditional sale agreement is valid under the Civil Code.
- Whether the arrangement constitutes an illegal mortgage, pledge, or antichresis (pactum commissorium).
- Remedy and enforcement
- Whether plaintiff is entitled to specific performance (delivery of property).
- Whether trial court erred in omitting findings on rents or damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)