G.R. No. L-10902 - Lagmay vs. Quinit

Patricio Basto, the registered owner of an undivided one‐half portion of the land covered by Original Certificate of Title No. 25620, sold his interest to the spouses of Emerenciana Quinit and Teodoro Gundran on October 12, 1929, for P280, with a redemption clause allowing repurchase within ten years.
The deed of conveyance, referred to as Exhibit “A”, contained a writing in the Ilocano dialect on the back page that played a significant role in subsequent disputes.

Patricio Basto’s right to repurchase the property was not exercised, as the redemption period lapsed.
In 1943, Emerenciana Quinit transferred the land to Florida Lagmay and Esteban Madruno for P450, based on the same deed which included the Ilocano writing, raising issues regarding the nature of this provision.

In July 1948, the present action (Civil Case No. 10330) was filed by plaintiffs Lagmay and Madruno against Quinit and her children, seeking enforcement of a formal deed of sale and possession of the land.
Earlier, in Civil Case No. 9859, Floserfida Basto (a relative of the late owner) had initiated a claim against Quinit, asserting ownership as successor of Patricio Basto based on a purported repurchase by the plaintiffs during the Japanese occupation.
The controversy in Case No. 9859 was amicably settled by the payment of P350 to Basto and P450 to plaintiffs Lagmay and Madruno, with both parties waiving any rights derived from the Ilocano writing, thereby extinguishing any claim arising from it.

At trial, the court found that the Ilocano writing on the back of Exhibit “A” was effectively a subrogation of the rights of Patricio Basto in favor of the plaintiffs’ spouses rather than evidencing an absolute sale by Quinit to them.
The trial court emphasized that, in light of the settlement in Case No. 9859, the plaintiffs had already received P450 and thereby waived any rights under the disputed writing.
Consequently, the trial court rendered judgment dismissing the plaintiffs’ complaint, holding that they no longer possessed any claim to the land in question.

Whether the writing, presented in the Ilocano dialect without an official translation, should be admitted into evidence.
The objection raised regarding its non-compliance with the requirements of an official language under the Rules of Court (Sec. 57, Rule 123).

Whether the writing should be interpreted as establishing a subrogation of Patricio Basto’s rights in favor of the plaintiffs’ spouses.
Alternatively, whether it could be construed as evidence of an absolute sale of the land by Quinit to the plaintiffs.

Whether the settlement in Civil Case No. 9859, whereby plaintiffs Lagmay and Madruno received P450 and waived their rights under the disputed writing, fully extinguished any further claims to the property.
The impact of such a waiver on the subsequent litigation and the interpretation of the disputed document.