Case Digest (G.R. No. L-26768) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case centers around Faustino Gojo, the petitioner-appellant, and respondents-appellees Segundo Goyala and Antonina Almoguera. The events unfolded after a "Deed of Pacto de Retro Sale" on May 26, 1951, where Goyala and Almoguera sold a parcel of agricultural land—approximately two and a half hectares—for P750.00, with a repurchase clause valid for one year. On July 4, 1951, an additional payment of P100.00 was made by the vendee, Gojo. Approaching ten years later, on April 12, 1961, Gojo filed a petition in the Court of First Instance of Sorsogon for consolidation of ownership, claiming that the vendors did not repurchase the land by the deadline. Conversely, Goyala filed an opposition stating that the true nature of their transaction was a cash loan disguised as a sale due to the Usury Law, and he claimed he attempted to repay the total sum of the loan—P810.00—on May 26, 1952, but this was rejected by Gojo. Subsequent to a series of procedural events, including the death of Case Digest (G.R. No. L-26768) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Transaction Background
- On May 26, 1951, respondents Segundo Goyala and his now-deceased wife Antonina Almoguera executed a "Deed of Pacto de Retro Sale" in favor of appellant Faustino Gojo involving a parcel of agricultural land of approximately two and one‐half hectares for a purchase price of P750.00.
- An additional amount of P100.00 was paid on July 4, 1951, as stipulated in the deed.
- Filing of the Petition for Consolidation of Ownership
- Approximately ten years after the deed’s execution, on April 12, 1961, appellant filed a petition with the Court of First Instance of Sorsogon requesting the consolidation of ownership of the land.
- Appellant contended that the repurchase period, fixed at May 26, 1952, had expired without the vendors exercising their right to repurchase, thereby vesting consolidated ownership in him.
- To update the Registry of Property, appellant sought a judicial order declaring such consolidation.
- Respondents’ Answer and Counterclaim
- On May 26, 1961, respondent Segundo Goyala filed an answer alleging that:
- The deed was not a true pacto de retro sale but a mechanism to secure a cash loan of P750.00.
- Additional sums of P50.00 and P10.00 had been lent to, and acknowledged by, the respondents, aggregating a total of P810.00.
- Segundo Goyala asserted that, on May 26, 1952, he tendered the entire sum of P810.00 in an effort to redeem the property, but appellant refused to accept payment or cancel the document.
- As a counterclaim, respondent prayed:
- For dismissal of appellant’s petition.
- That the document be declared a mortgage (and not a pacto de retro sale) and canceled.
- Payment of an annual yield of P1,800.00 representing the land’s product value.
- Alternatively, if deemed a true pacto de retro sale, that appellant execute a deed of resale or repurchase in compliance with Civil Code provisions.
- Subsequent Proceedings in the Lower Court
- With the death of respondent Antonina Almoguera (notified on December 1, 1962), the trial court ordered the substitution of her heirs as defendants in place of the deceased.
- Appellant was directed to file an amended complaint, but on February 15, 1963, the trial court dismissed the complaint without prejudice due to appellant’s failure to comply within the prescribed period.
- On July 10, 1963, respondent Segundo Goyala moved to declare appellant in default with respect to the counterclaim, which was granted on July 11, 1963.
- The Clerk of Court received evidence supporting the counterclaim, and on November 15, 1963, the trial court rendered a judgment in favor of respondent Segundo Goyala:
- Declaring the deed (Exhibit 'A') as an equitable mortgage rather than a pacto de retro sale.
- Allowing the respondents, including the heirs of Antonina Almoguera, to redeem the property upon delivery of the P810.00 tendered.
- Ordering appellant to restore possession of the property to the respondents.
- An amendment to the judgment on December 19, 1963, added the directive for appellant to deliver and restore possession of the land.
- Appellate Proceedings and Assigned Errors
- Appellant challenged the trial court’s decisions before the Court of Appeals, which, identifying that the issues involved were purely questions of law, certified the case to the Supreme Court.
- The appellant’s assignable errors included:
- The erroneous declaration of default regarding the compulsory counterclaim.
- Improper deputization of the Clerk of Court to receive respondents’ evidence.
- Wrongful judgment in favor of respondents allowing redemption of the land for P810.00.
- The appellant argued that the counterclaim was compulsory—automatically joined with the complaint—and that the dismissal of the complaint was based on a void order regarding the substitution of deceased parties.
Issues:
- Whether the trial court erred in declaring appellant in default on the compulsory counterclaim, given that such counterclaims are automatically joined with the complaint.
- Whether the trial court improperly required appellant to amend his complaint for substituting the deceased respondent rather than ordering the appearance of the legal representatives as mandated by the Rules of Court.
- Whether the lower court’s directive to have the Clerk of Court receive respondents’ evidence was legally proper.
- Whether the trial court’s judgment—declaring the document an equitable mortgage and ordering redemption of the land for P810.00—was erroneous based on the evidence and applicable law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)