Facts:

This case involves Alfonso Araneta as the plaintiff and appellant, and Marta Cui Vda. de Sanson as the defendant and appellee. The case originated from a transaction that took place on June 17, 1941, when Alfonso Araneta and his spouse, Dolores Bobadilla, sold two parcels of land located in Cebu City to Julian Sanson and his wife, Marta Cui, for the sum of P2,000. This sale came with a provision allowing the vendors to repurchase the property within one year, alongside a stipulation that they could continue to rent the property for P20 per month while awaiting the repurchase. The vendors, however, failed to exercise their right within the stipulated timeframe of one year, thus Julian and Marta Sanson became the absolute owners of the property.

Years later, following the death of her husband, Marta Sanson, out of generosity, resold the properties back to Alfonso and Dolores for the original purchase price of P2,000, plus an additional P1,000 for unpaid rents. Subsequently, Alfon

...

Facts:

Transaction Between Parties

• On June 17, 1941, Alfonso Araneta and his wife Dolores Bobadilla sold two parcels of land with improvements in the City of Cebu to Julian Sanson and his wife Marta Cui.
• The agreed sale price was P2,000, with the added provision granting the vendors a right to repurchase the property within one year.
• It was expressly provided that, pending the exercise of their right of repurchase, the vendors could continue to occupy the property as lessees, subject to the payment of rent at P20 per month (as evidenced by Exhibit A).
• The stipulated period for repurchase expired without the vendors exercising their right, thereby rendering the vendees the absolute owners of the property.

Subsequent Resale and Payment of Back Rents

• On June 24, 1946, Marta Cui Vda. de Sanson (widow of Julian Sanson, who had already deceased) resold the two parcels of land back to Alfonso Araneta and Dolores Bobadilla.
• The resale was executed at the same price of P2,000, with an additional sum of P1,000 representing unpaid rents.
• This reconveyance was characterized as an act of charity or generosity on the part of the appellee.

Dispute and Legal Action

• Alfonso Araneta, after seeking advice from several lawyers who indicated he was not obligated to pay the back rents, later attempted to recover the P1,000 from Marta Cui Vda. de Sanson when she refused reimbursement.
• He initiated an action for collection in the Court of First Instance of Cebu (Civil Case No. E-27).
• The lower court rendered judgment favoring the defendant, absolving her of the obligation to return the payment, which led to the present appeal.

Context of the Debt Moratorium

• The appellant contended that his payment of P1,000 was premised on the provisions of Executive Order No. 25, as amended by Executive Order No. 82 on debt moratorium.
• He argued that this law should facilitate the recovery of his payment, given that payment was said to have been made prematurely.
• The jurisprudence, however, clarifies that the debt moratorium does not condone the repudiation of debts but merely delays the payment obligation during the period of its enforcement.

Issue:

Applicability of the Debt Moratorium Law

• Whether the provisions of Executive Order No. 25 (as amended by EO No. 82) entitle the appellant to recover the payment of P1,000 made for unpaid rents.
• Whether the law on debt moratorium, which suspends the collection and payment obligations, supports the appellant's contention for a refund.

Contractual Conditions Governing the Right of Redemption

• Whether the stipulation in the deed of sale conditioning the right of redemption on the payment of back rent was lawfully applicable.
• Whether the appellant’s right to repurchase (redemption) was effectively forfeited due to his delinquency in rent payments as provided under the original agreement.

Implications of Voluntary Payment

• Whether the appellant’s voluntary payment of the P1,000 constituted a waiver of his right to invoke the debt moratorium provisions.
• Whether his action in paying the amount, despite available statutory relief, indicates an acceptance of the contractual obligation to pay the back rents.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)