Facts:

In the case of Leonardo Lucido vs. Gelasio Calupitan et al., decided on March 17, 1914, the plaintiff, Leonardo Lucido, initiated a legal action against the defendants, Gelasio Calupitan and others, concerning a dispute over property rights. The events leading to the case began on February 10, 1903, when certain chattels and real estate owned by Lucido were sold at an execution sale to a buyer named Rosales. The following day, Rosales transferred a half interest in the property to Zolaivar. Subsequently, on March 30, 1903, a public document was executed, signed by all parties involved, including Calupitan, which stated that Rosales and Zolaivar, with Lucido's consent, sold all their rights and obligations related to the property to Calupitan for a total of 1,687 Mexican dollars, plus interest.

On the same day, Lucido and Calupitan executed another document wherein Calupitan certified that he had delivered the instrument to Lucido, indicating that he ceded all irrigat...

Facts:

• Execution Sale and Subsequent Transfer: On February 10, 1903, chattels and real estate owned by Leonardo Lucido were sold at an execution sale to Rosales, who transferred a one-half interest to Zolaivar the following day.
• Agreement with Calupitan: On March 30, 1903, Rosales, Zolaivar, Lucido, and Gelasio Calupitan executed a public document wherein Rosales and Zolaivar transferred their rights in the property to Calupitan for the purchase price plus 1% monthly interest pending redemption.
• Repurchase Agreement: On the same day, Lucido and Calupitan signed a document allowing Lucido to repurchase the property after three years.
• Lower Court Findings: The lower court ruled that the agreement constituted a sale with conventional redemption under articles 1507 et seq. of the Civil Code. It held that the redemption period had not expired and that Lucido had validly tendered the redemption price to Calupitan.
• Appeal: Calupitan appealed, challenging the lower court’s rulings on the nature of the transaction, the redemption period, and the sufficiency of the tender.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Character of the Transaction: The agreement’s terms and the parties’ actions indicated that the transaction was a sale with the right of conventional redemption. The three-year suspension of the redemption right and the subsequent four-year redemption period were consistent with the Civil Code.
2. Redemption Period Calculation: The Court clarified that the redemption period begins after the suspension period, aligning with the Civil Code’s intent to balance the interests of the parties and public policy.
3. Tender of Redemption Price: A valid tender of the redemption price is sufficient to exercise the right of redemption, even if the amount is not immediately paid.
4. Third-Party Rights: The provisions of the Civil Code protect the vendor’s right to redeem against subsequent transferees who have knowledge of the redemption right.
5. Public Policy: The Court emphasized the importance of stabilizing property titles and preventing undue delays in redemption, consistent with the Civil Code’s objectives.