Title
Bandong vs. Austria
Case
G.R. No. 9785
Decision Date
Sep 24, 1915
In Bandong v. Austria, the court ruled that a provision in a written contract for the sale of land allowed the vendors to repurchase the land within a period of ten years, despite the statutory limitation of four years, resulting in a reversal of the trial court's judgment in favor of the vendors.
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Case Digest (G.R. No. 56566)

Facts:

  • Case: Bandong v. Austria, G.R. No. 9785, decided on September 24, 1915.
  • Plaintiffs-appellants: Isabela Bandong and Juan Ferrer.
  • Contract date: April 29, 1905, with Antonio Ventenilla, the original vendee of a parcel of land.
  • Contract terms: Vendors retained the right to repurchase the land for P350 without interest on the money or products derived from the land.
  • Repurchase allowed in "the month of March of any year."
  • After Ventenilla's death, his widow, Alejandra Austria, became the defendant-appellee.
  • In March 1913, Bandong and Ferrer attempted to repurchase the land, but Austria refused, claiming the right had prescribed.
  • Trial court ruled in favor of Austria, stating the right to repurchase expired four years after the contract date, based on Article 1508 of the Civil Code.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the plaintiffs-appellants, reversing the trial court's decision.
  • The Court held that the written contract allowed the vendors to repurchase the land within ten years from the contract date. ...(Unlock)

Ratio:

  • The Court determined that the contract's provision constituted an express agreement for repurchase in March of any year following the contract's date.
  • Article 1508's four-year limitation applies only when there is no express agreement regarding the redemption period.
  • The contract explicitly allowed for a ten-year repurchase period, making...continue reading

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