G.R. No. 157171 - Garcia vs. Court of Appeals

Plaintiff/Appellee: Patricio Alifio, who initiated the suit seeking the absolute title to the land and damages.
Defendants/Appellants: Fortunato Adove et al., who contested the plaintiff's claims and asserted their right of redemption.

A land sale was executed on May 14, 1906, whereby the defendants sold the land to the plaintiff with an attached right to repurchase (pacto de retro).
The deed of sale did not specify a period within which the redemption was to be exercised, thereby triggering the application of the legal period as provided by law.

The defendants contended that the sale was undertaken with a right to repurchase and that no explicit time frame was fixed in the deed.
They claimed that they tendered the redemption price of P1,573 on May 14, 1915—purportedly attempting to exercise their right within a reinterpreted ten-year period.
In furtherance of their claims, the defendants stated that:

Prior to the expiration of the legal period, on May 14, 1915, they made a formal offer by tendering the redemption sum.
Due to the agricultural significance of the land (with seven parcels planted to sugar cane for milling in 1916), an ancillary agreement was reached between the parties regarding the milling operation.
Even after completion of mowing in July 1916, when the defendants again sought to redeem the land by depositing the redemption amount at the justice of the peace court of Balayan, the plaintiff refused to accept the money, thereby leading to a request for judicial intervention.

The plaintiff sought an order declaring his title to the land absolute, on the ground that the defendants’ right of redemption had long lapsed as provided by law.
He prayed for a judgment making absolute the prior writ of preliminary injunction, effectively nullifying any redeemed interest by the defendants.
Additionally, the plaintiff requested damages amounting to P2,000 and reimbursement of the costs incurred in the proceedings.
The plaintiff maintained that the defendants’ attempts to redeem the land (including the 1915 tender and subsequent offer) were invalid as the legal period for redemption had expired, thus precluding any further contractual novation.

Whether the defendants’ right of redemption could be validly exercised on May 14, 1915, when the deed of sale did not specify the period within which redemption was to occur.

Whether the legal redemption period, in the absence of a stipulated period, should be interpreted as four years under the Civil Code.
Whether the defendants’ conduct in tendering redemption funds in 1915 and later depositing the amount in court constitutes a legitimate exercise of the right to repurchase.
Whether the sugar cane milling agreement, entered into for the year 1916, has any effect on resetting or extending the redemption period.
Whether the subsequent offer to redeem, even if accompanied by the fulfillment of certain conditions, can override the expiration of the legally prescribed period for redemption.