Title
Alderete vs. Amandoron
Case
G.R. No. 22588
Decision Date
Nov 13, 1924
Plaintiff vendee under *pacto de retro* sale sued vendor-tenants for possession due to unpaid rent; Supreme Court ruled in favor of plaintiff, affirming jurisdiction and estoppel.
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Case Digest (G.R. No. 22588)

Facts:

  1. 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).
  2. 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.
  3. 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.
  4. 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.
  5. 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:

  1. 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.
  2. 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.
  3. 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.


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