Case Digest (G.R. No. L-11346)
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...
Case Digest (G.R. No. L-11346)
Facts:
- On December 4, 1913, the plaintiff, Espiridiona Canuto, executed a deed of sale conveying a parcel of land to the defendant, Juan Mariano, for the sum of P360.
- Notably, the deed reserved the plaintiff's right to repurchase the land for the same amount within one year from the date of the sale.
Transaction Background
- As the original redemption period was nearing its expiration, on December 2, 1914, the plaintiff sought an extension of time to repurchase the land.
- The plaintiff testified that while engaged in her daily activities near a well, she encountered the defendant and requested an extension, assuring him that she would secure the money and consummate the repurchase during the month of December 1914.
- The defendant, after some hesitation, orally agreed to extend the redemption period to the end of December 1914.
- It was further agreed that on the following day, the plaintiff was to meet the defendant at the office of an attorney (Mercado) at 4 o’clock, where the purchase price was to be paid, and the necessary documents would be executed.
Oral Agreement to Extend the Redemption Period
- The plaintiff, acting diligently, obtained the money and duly presented herself at the attorney’s office at the agreed time, waiting until dark.
- Despite her readiness and repeated demands, the defendant failed to appear at the scheduled meeting and subsequently refused to execute a deed of resale or reserve the agreed purchase price, thereby obstructing her right to repurchase.
Plaintiff’s Performance and Defendant’s Noncompliance
- The plaintiff’s testimony was corroborated by witness Severino Pascual, who attested to the occurrence of the oral agreement for an extension.
- In contrast, the defendant’s conflicting testimony, which claimed that the redemption period originally expired on December 4, 1914, was found to be vague and incredible by the trial judge.
- The trial record did not reveal any discrepancies capable of disturbing the finding that the plaintiff's account was substantially true.
Conflicting Testimonies and Evidence
- The case is an appeal from the judgment of the Court of First Instance of Manila, which had entered an order for the execution of the repurchase deed.
- The defendant set up a claim of absolute ownership of the property, asserting that the redemption period had expired, thereby denying the plaintiff’s renewed right to repurchase based on the alleged oral agreement.
Procedural Posture
Issue:
- Whether the oral agreement to extend the redemption period is admissible to vary, modify, or contradict the terms of the written deed of sale.
Admissibility of Extrinsic Evidence
- Whether the expiration of the written redemption period automatically nullifies the plaintiff’s reserved right to repurchase the property.
Effect of Expiration of the Original Redemption Period
- Whether the plaintiff’s failure to make a judicial deposit, in light of the defendant’s refusal to receive the purchase price as agreed, results in the forfeiture of her right to repurchase.
Timeliness and Performance of the Tender
- Whether the defendant may validly repudiate his promise to extend the redemption period when the plaintiff was ready and willing to perform within the extended period.
Defendant’s Accountability
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)