Title
Balila vs. Intermediate Appellate Court
Case
G.R. No. L-68477
Decision Date
Oct 29, 1987
The Supreme Court ordered the reconveyance of two parcels of land in Pangasinan, classifying the contract as an equitable mortgage and acknowledging that subsequent actions novated the original compromise judgment.
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Case Digest (G.R. No. L-68477)

Facts:

  • The case involves the Spouses Aniceto Balila and Editha S. de Guzman, Spouses Asterio de Guzman and Erlinda Concepcion, and Encarnacion Ocampo Vda. de Concepcion as petitioners.
  • Respondents include the Honorable Intermediate Appellate Court, Judge Florante S. Abasolo, and private respondents Guadalupe C. Vda. de del Castillo and Waldo del Castillo.
  • A civil case (Civil Case No. U-3501) was filed in 1980, leading to an amicable settlement approved by the trial court.
  • The settlement involved the petitioners selling two parcels of land under a pacto de retro sale for P84,000, with a payment deadline of May 15, 1981.
  • The petitioners failed to pay the full amount by the deadline.
  • On December 30, 1981, they redeemed a different parcel of land (Lot No. 52) by paying P20,000.
  • In August 1982, Guadalupe filed a motion for consolidation of title over the remaining parcels due to non-payment.
  • The trial court issued an order on April 26, 1983, consolidating ownership in favor of Guadalupe.
  • The petitioners made partial payments after the deadline, including P28,800 on June 8, 1983, leaving a balance of P35,200.
  • They later filed a petition for certiorari and prohibition with the Intermediate Appellate Court, which upheld the trial court's decision.
  • The petitioners contended that the contract was an equitable mortgage, not a pacto de retro sale, and that the original decision had been novated by subsequent agreements.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found merit in the petitioners' arguments and ruled in their favor.
  • The decision of the Intermediate Appellate Court was set aside.
  • Private respondents were ordered to reconvey and deliver Lot No. 965 and Lot No. 16 to the petitioners.
  • The Clerk of Court was directed to execute the necessary deed of reconveyance if the private respondents failed to co...(Unlock)

Ratio:

  • The Supreme Court emphasized that the issues arose from a judgment by compromise based on a legally binding amicable settlement.
  • The court noted that the petitioners made several partial payments and received multip...continue reading

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