Case Digest (G.R. No. L-13783)
Facts:
The case involves Francisco Capalungan as the plaintiff and appellee, and Fulgencio Medrano as the defendant and appellant. The events leading to the case began on May 3, 1931, when Francisco Capalungan executed a deed titled "compraventa con pacto de retro" in favor of Fulgencio Medrano, transferring ownership of a parcel of land located in San Laureano, No. 18, Dingras, Ilocos Norte, for the sum of P1,200.00. This contract granted Capalungan the right to repurchase the land within ten years, while also stipulating that Medrano could not dispose of the land during the contract's validity but could enjoy possession of it. On January 31, 1933, Capalungan executed a similar deed for another parcel of land in favor of Pedro Medrano, which contained similar provisions. On May 22, 1944, Capalungan attempted to redeem both parcels by paying Pedro Medrano a total of P1,800.00. Subsequently, Fulgencio and Pedro Medrano filed a suit in the Court of First Instance of Iloc...
Case Digest (G.R. No. L-13783)
Facts:
Background of the Case
- On May 3, 1931, Francisco Capalungan executed a "compraventa con pacto de retro" (sale with pact to repurchase) in favor of Fulgencio Medrano for a parcel of land in San Laureano, No. 18, Dingras, Ilocos Norte, for P1,200.00. The contract allowed Capalungan to repurchase the land within ten years, but Medrano could not dispose of the land during this period and only had the right to possess it.
Second Contract
- On January 31, 1933, Capalungan executed a similar deed in favor of Pedro Medrano for another parcel of land in the same sitio, with the same terms as the first contract.
Repurchase Attempt
- On May 22, 1944, Capalungan paid Pedro Medrano P1,800.00 to redeem both parcels of land. Fulgencio and Pedro Medrano then filed a suit to annul the repurchase, claiming Capalungan had lost the right to repurchase and that ownership had been consolidated in their favor.
Trial Court Decision
- The trial court ruled that the contracts were equitable mortgages. It declared the redemption of the land mortgaged to Pedro Medrano valid but invalidated the redemption of the land mortgaged to Fulgencio Medrano. The court ordered Fulgencio Medrano to receive P1,200.00 and Pedro Medrano to receive P600.00, with possession of the land returned to Capalungan.
Appeal and Subsequent Action
- The Court of Appeals affirmed the trial court's decision. On June 23, 1954, Capalungan filed another action against Fulgencio Medrano, alleging that he had tendered P1,200.00 for redemption, but Medrano refused to accept it. Capalungan sought damages and delivery of palay received by Medrano.
Lower Court Ruling
- The lower court ordered Medrano to deliver 10 1/2 uyones of palay (or P577.50) and pay P100.00 in moral damages. It also directed Capalungan to seek a writ of execution for the Court of Appeals' decision in Civil Case No. 235.
Issue:
- Whether the lower court erred in ordering Capalungan to seek a writ of execution for the Court of Appeals' decision in Civil Case No. 235.
- Whether Medrano was justified in refusing Capalungan's tender of payment.
- Whether the redemption price should be P1,205.50 instead of P1,200.00.
- Whether Medrano should be liable for delivering palay and paying moral damages.
Ruling:
- The Supreme Court modified the lower court's decision. It held that:
- The lower court erred in ordering Capalungan to seek a writ of execution, as the Court of Appeals' decision did not require any action from Medrano.
- Medrano was not liable for damages or delivery of palay because Capalungan failed to consign the payment, which is necessary to extinguish the obligation.
- The redemption price remained P1,200.00, as there was no evidence that Medrano paid the P5.50 registration fee.
- Medrano was ordered to accept payment of P1,200.00 and execute the proper release documents.
Ratio:
- Nature of the Contract: The contracts were deemed equitable mortgages, not sales with a pact to repurchase. As such, Capalungan was discharging an obligation, not exercising a privilege.
- Tender of Payment and Consignation: Under Article 1256 of the Civil Code, tender of payment without consignation does not constitute valid payment. Since Capalungan did not consign the amount, the obligation was not extinguished, and Medrano retained the right to possess the land and its fruits.
- Redemption Price: The court found no basis to increase the redemption price to P1,205.50, as there was no evidence that Medrano incurred the P5.50 expense.
- Damages and Fruits: Medrano could not be held liable for damages or delivery of palay because the obligation was not discharged due to the lack of consignation.