Facts:

On April 29, 1905, plaintiffs Isabela Bandong and Juan Ferrer sold a parcel of land to Antonio Ventenilla for P350, explicitly reserving the right to repurchase the land under terms specified in the deed of sale. The contract stated that the vendors had the right to repurchase the land at the original price without any considerations for interest or the land's produce, provided they exercised this right in the month of March of any year. Following the sale, Ventenilla passed away, and his widow, Alejandra Austria, succeeded in title. On March of 1913, less than eight years after the contract was executed, the vendors offered to repurchase the land, but their offer was declined by the defendant on the grounds that the right of repurchase had prescribed. The lower court ruled that the right to repurchase had expired after four years based on Article 1508 of the Civil Code, which establishes a four-year limitation period for t

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Facts:

Transaction and Contract Formation

• On April 29, 1905, the plaintiffs sold a parcel of land to Antonio Ventenilla for P350.
• The deed of sale explicitly reserved a right for the plaintiffs to repurchase said land.
• The contract contained a specific stipulation stating that the vendors would repurchase the land at the same price, without any provision for interest on the money or for the products of the land, but expressly in the month of March of any year.

Express Right to Repurchase

• The parties’ agreement clearly provided that the vendors could exercise their right to repurchase in the month of March immediately following the contract’s execution and in any subsequent March within an extended period.
• The contractual language left no ambiguity regarding the vendors’ entitlement to repurchase at the predetermined time rather than being bound by the general statutory limitations.

Subsequent Developments and Contention

• The vendors attempted to exercise their repurchase right in March 1913.
• This offer was rejected by the vendee’s estate on the ground that the right to repurchase had prescribed.
• The defendant, Alejandra Austria (the widow of the original vendee), contended that the repurchase right had expired due to the statutory prescription.

Procedural History and Judicial Findings

• The lower court ruled that the right to repurchase had expired after a statutory period of four years from the contract date, relying on article 1508 of the Civil Code in the absence of any express agreement to the contrary.
• The case was then elevated on appeal, challenging whether the statutory limitation should indeed apply when an express contract stipulation extended the repurchase period.

Issue:

Whether the express stipulation in the contract allowing repurchase in the month of March for any year overrides the statutory limitation of four years from the date of the contract.

• Does the agreement between the parties create an exception to the default period prescribed by article 1508 of the Civil Code?

Whether the repurchase offer made in March 1913 falls within the period during which the vendors’ right to repurchase remains valid.

• Given the explicit provision in the contract, is the vendors’ repurchase action in March 1913 legally enforceable?

How the express nature of the repurchase clause interacts with the statutory provisions allowing for a repurchase period of up to ten years by express agreement.

• Should the statute’s limitation of four years be considered binding when there is a mutually agreed contractual provision for a longer period?

• The broader judicial question regarding the primacy of clearly expressed contractual agreements over default statutory limitations when such express terms are provided.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)