Facts:

The case of Espiridiona Canuto vs. Juan Mariano revolves around a dispute regarding the repurchase of a parcel of land. The events leading to the case began on December 4, 1913, when the plaintiff, Espiridiona Canuto, executed a deed of sale transferring ownership of a parcel of land to the defendant, Juan Mariano, for the sum of P360. The deed included a provision allowing Canuto to repurchase the land within one year. As the redemption period expired without Canuto exercising her right, Mariano claimed absolute ownership of the property. However, Canuto contended that an oral agreement was made with Mariano to extend the redemption period until the end of December 1914.

On December 2, 1914, Canuto approached Mariano to request this extension, promising to secure the funds necessary for the repurchase. Mariano allegedly agreed to this extension. Canuto testified that she later went to Mariano's house to finalize the transaction, but he failed to appear at th...

Facts:

1. Initial Transaction:
On December 4, 1913, Espiridiona Canuto (plaintiff) sold a parcel of land to Juan Mariano (defendant) for P360. The deed of sale included a reservation of the right to repurchase the land within one year from the date of the sale.

2. Expiration of Redemption Period:
The original redemption period expired on December 4, 1914. The plaintiff failed to exercise her right of repurchase within this period.

3. Alleged Oral Agreement for Extension:
The plaintiff claimed that on December 2, 1914 (two days before the expiration of the redemption period), she requested an extension from the defendant. She alleged that the defendant orally agreed to extend the redemption period until the end of December 1914, provided she repurchased the land within that time.

4. Attempted Repurchase:
The plaintiff testified that she arranged to meet the defendant at the office of Attorney Mercado on December 3, 1914, to complete the repurchase. She brought the money but the defendant failed to appear. She later went to his house but was told he was not home.

5. Defendant’s Refusal:
The defendant refused to honor the alleged oral agreement, asserting that the redemption period had expired on December 4, 1914, and that the plaintiff no longer had the right to repurchase the land.

6. Witness Corroboration:
Severino Pascual, a witness, corroborated the plaintiff’s testimony regarding the oral agreement for the extension of the redemption period.

7. Trial Court Findings:
The trial court accepted the plaintiff’s testimony as credible and rejected the defendant’s conflicting testimony, which was deemed vague and unreliable.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Validity of Oral Agreements Modifying Written Contracts:
   The Court held that the rule prohibiting parol evidence to alter, vary, or contradict a written instrument does not apply to subsequent oral agreements between the parties. Such agreements, if proven, can modify or extend the terms of the original written contract.

2. Sufficiency of Tender of Payment:
   The Court reiterated the settled rule in Philippine jurisprudence that a bona fide offer or tender of the purchase price is sufficient to preserve the right to repurchase, even if the other party refuses to accept it. Judicial deposit is not required in such cases.

3. Preservation of Right to Repurchase:
   The Court emphasized that the plaintiff’s diligent efforts to repurchase the land within the extended period, coupled with the defendant’s refusal to accept payment, did not result in the loss of her right to repurchase. The failure to complete the repurchase was due to circumstances beyond her control.

4. Credibility of Witnesses:
   The Court upheld the trial court’s findings regarding the credibility of the plaintiff’s testimony and the corroborating witness, while rejecting the defendant’s testimony as unreliable.