Title
Espana vs. Lucido
Case
G.R. No. L-3568
Decision Date
Aug 23, 1907
A contract of sale with the right of repurchase is deemed unenforceable due to the expiration of the prescribed period, leading to the defendant's acquittal and plaintiff bearing costs.
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Case Digest (G.R. No. L-3568)

Facts:

  • The case involves a contract dated January 5, 1892, between Roman Espana, Carmen Formentera, and Manuel Lucido.
  • The contract pertained to the sale of coconut and rice lands for 500 pesos, including a clause for the sellers to repurchase the property when financially able.
  • This arrangement is classified as a sale with a right to repurchase under Article 1507 of the Civil Code.
  • The contract was executed during the Philippine Revolution against Spanish rule.
  • The plaintiffs did not attempt to repurchase the property until November 27, 1905, raising concerns about the validity of their claim due to the time elapsed.
  • The lower court ruled that the statute of limitations was interrupted by the war starting in August 1896, asserting that courts were non-operational until July 1, 1901.
  • This assertion was contested, as records showed that courts were functioning until at least April 15, 1898.
  • The case was escalated to the Supreme Court to assess the statute of limitations in the context of the contract and historical events.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the defendant, Leonardo Lucido, reversing the lower court's decision.
  • The Court determined that the plaintiffs' right to repurchase had expired, thus their action could not be maintained.
  • The Court found that the statute of limitations was ...(Unlock)

Ratio:

  • The Court's decision was based on the interpretation of the Civil Code, particularly Articles 1507 and 1508, which govern sales with a right to repurchase.
  • The right to repurchase must be exercised within a specified period, typically four years unless an express agreement allows for a longer period, not exceeding ten years.
  • The plaintiffs failed to exercise their right within the statutory timeframe, which expired on Ja...continue reading

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