Case Digest (G.R. No. L-15128) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 26, 1950, Segundo Fernando executed a deed of mortgage in favor of Cecilio Diego over two parcels of land registered in his name to secure a ₱2,000 interest‐free loan payable in four years (Exhibit “A”). Possession of the mortgaged parcels was turned over to Diego immediately. When Fernando failed to pay upon maturity, Diego made several demands which remained unheeded. Diego then filed Civil Case No. 1694 in the Court of First Instance of Nueva Ecija for foreclosure of mortgage, alleging nonpayment. Fernando defended by insisting that the true agreement was one of antichresis, not mortgage, and that Diego had already been paid in kind through the delivery of 120 cavans of palay valued at ₱5,200, exceeding the loan, and that Diego owed him a refund. The trial court found the deed to be a true mortgage, held that possession alone did not convert it into antichresis, and determined that Diego had received only 65 cavans of palay. It rendered judgment for the full ₱2,000 plu Case Digest (G.R. No. L-15128) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Mortgage execution and terms
- On May 26, 1950, defendant Segundo Fernando executed a deed of mortgage (Exhibit “A”) over two registered parcels of land to secure a loan of ₱2,000, without interest, payable within four years.
- Possession of the mortgaged properties was delivered to mortgagee Cecilio Diego.
- Debtor’s default and foreclosure action
- Defendant failed to repay the loan at the end of the four‐year term despite repeated demands.
- Diego filed an action for foreclosure of mortgage; Fernando contended the contract was one of antichresis and claimed that Diego had collected 120 cavans of palay valued at ₱5,200, thereby overpaying the debt by ₱2,720.
- Trial court findings and judgment
- The Court of First Instance held that Exhibit “A” evidenced a true mortgage, noting that transfer of possession alone did not convert it into antichresis, and found that Diego collected only 65 cavans.
- Judgment awarded Diego ₱2,000 with legal interest from filing, ₱500 attorney’s fees, costs, and foreclosure upon default.
Issues:
- Whether the contract between the parties is a mortgage or an antichresis.
- Whether legal interest may be awarded from the filing of the action despite the mortgagee’s possession and enjoyment of fruits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)