Case Digest (G.R. No. 22588)
Facts:
The case of Leon Alderete vs. Gregorio Amandoron and Juliana Angosto revolves around a dispute regarding the possession of two parcels of land sold under a pacto de retro agreement. On December 10, 1918, the defendants, Amandoron and Angosto, sold the land to the plaintiff, Alderete, while retaining the right to repurchase it. Following the sale, the defendants continued to occupy the land as tenants, with Alderete never taking actual possession. For the year 1920, the defendants paid rent in the form of one-third of the crop yield; however, they failed to pay rent for 1921. Consequently, Alderete initiated an action for forcible entry and detainer in the Justice of the Peace Court of Alimodian, Iloilo, claiming that the defendants' non-payment of rent constituted a breach of their lease agreement, thereby forfeiting their right to possess the land. The Justice of the Peace Court ruled in favor of the defendants, leading Alderete to appeal to the Court of First Instance. ...
Case Digest (G.R. No. 22588)
Facts:
- Transaction Details: On December 10, 1918, defendants Gregorio Amandoron and Juliana Angosto sold two parcels of land to plaintiff Leon Alderete under a pacto de retro (sale with the right to repurchase).
- Occupancy and Tenancy: After the sale, the defendants remained in possession of the land as tenants of the plaintiff. The plaintiff was never in actual physical possession of the land.
- Rent Payment: The defendants paid rent in the form of a one-third share of the crop for the year 1920 but failed to pay rent for the year 1921.
- Legal Action: The plaintiff filed an action for forcible entry and detainer in the justice of the peace court of Alimodian, Iloilo, seeking possession of the land on the grounds that the defendants breached their lease contract by failing to pay rent.
- Court Proceedings: The justice of the peace court ruled in favor of the plaintiff, but on appeal, the Court of First Instance of Iloilo absolved the defendants, holding that the plaintiff admitted he was not the owner of the land and that the sale was made to secure a debt.
Issue:
- Whether the justice of the peace court had jurisdiction over the action for forcible entry and detainer, given that the transaction involved a pacto de retro sale.
- Whether the plaintiff, as the vendee under a pacto de retro sale, had the right to maintain an action for possession against the defendants (vendors) for non-payment of rent.
- Whether the defendants, as tenants, were estopped from disputing the plaintiff’s title and right to possession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
CONCURRING OPINION
Justice Johnson concurred, emphasizing that a vendee under a pacto de retro sale may maintain an action for forcible entry and detainer against the vendor-turned-tenant for non-payment of rent. The vendor cannot raise the issue of ownership unless they first comply with the terms of the repurchase.