Facts:

The case of Agustin Asencio v. Roman Bautista et al. (G.R. No. 10559) revolves around a dispute regarding the ownership of a parcel of land. The events leading to the appeal took place in the Philippines, culminating in a judgment by the Supreme Court on March 16, 1917. The plaintiff, Agustin Asencio, initiated a complaint claiming ownership of land previously owned by the defendant, Roman Bautista. The background reveals that Bautista originally owned the property and executed a deed of sale to Antonio Baladjay. However, Baladjay failed to pay the purchase price of P3,500, resulting in Bautista retaining possession of the land. The situation escalated when Baladjay, unable to fulfill his financial obligation, reconveyed the property back to Bautista through an unregistered private deed. In a later transaction, Baladjay sold all his lands, including the disputed property, to Asencio for P543, while retaining a right to repurchase. This deed, however, was duly acknowledged before

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Facts:

Background of the Transaction

• The property in dispute was originally owned by the defendant, Roman Bautista.
• Bautista executed a deed of sale transferring the property to Antonio Baladjay.
• Possession was not delivered because the purchase price of ₱3,500 was not paid by Baladjay.

Subsequent Transactions and Documents

• Baladjay, unable to pay the purchase price, reconveyed the land back to Bautista through a deed of reconveyance executed in a private document.
• Later, Baladjay—who was indebted to Agustin Asencio—executed a deed of conveyance transferring all his lands, including the disputed parcel, to Asencio for the sum of ₱543.
• This deed of conveyance included a reservation of the right to repurchase by the vendor and was duly acknowledged before a notary public, thereby constituting a public document.

Noticeable Procedural and Temporal Issues

• The right to repurchase under the deed of conveyance had expired before the action was instituted.
• None of the documents (the deed of sale, deed of reconveyance, or the deed of conveyance) was registered.
• The deed of reconveyance executed by Baladjay was antidated in relation to the deed of conveyance in favor of Asencio.

Possession and Title Implications

• Bautista had already secured possession of the land before the deed of conveyance to Asencio was executed.
• Under Article 1473 of the Civil Code, the possession held by Bautista coupled with the reconveyance document implies that Bautista is deemed the owner of the parcel.

Issue:

Priority of Title and Possession

• Whether the deed of reconveyance—which returned the land to Bautista and was executed prior to the deed of conveyance—takes precedence over the notarized deed of conveyance in favor of Asencio.
• How the lack of registration of the deeds affects the determination of title.

Evidentiary Weight of Documentary Recitals

• Whether the recital in the deed of conveyance stating the purchase price has been received is deemed conclusive.
• The extent to which such recitals can or cannot be contradicted when the evidence overwhelmingly indicates otherwise.

Effect of the Right of Repurchase

• Whether the reserved right to repurchase in the deed of conveyance has any bearing given that the time to exercise it had already expired prior to the commencement of the litigation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)