Title
Supreme Court
Nool vs. Court of Appeals
Case
G.R. No. 116635
Decision Date
Jul 24, 1997
Plaintiffs claimed ownership of foreclosed lands, alleging a repurchase agreement with defendant Anacleto. Courts ruled the sale void due to lack of title, nullifying repurchase rights, and ordered restitution of P30,000 with rent payments.

Case Digest (G.R. No. 116635)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties
    • Two parcels of land are in dispute: one hectare formerly owned by Victorino Nool (TCT No. T-74950) and 3.0880 hectares formerly owned by Francisco Nool (TCT No. T-100945), both located in San Manuel, Isabela.
    • Plaintiffs-appellants: Conchita Nool and Gaudencio Almojera (her husband), claim ownership, having bought the lands from Victorino and Francisco Nool, Conchita’s brothers.
    • Defendants-appellees: Anacleto Nool (younger brother of Conchita) and Emilia Nebre, holders of the titles after purchasing from the Development Bank of the Philippines (DBP).
  • Circumstances Leading to Litigation
    • Plaintiffs obtained a loan from DBP, secured by a real estate mortgage on the land still registered under Victorino and Francisco Nool.
    • Plaintiffs failed to pay the loan totaling ₱56,000.00 plus interest and surcharges; mortgage was foreclosed.
    • Within the redemption period, Anacleto Nool redeemed the foreclosed properties from DBP, and titles of both parcels were transferred to him.
    • Plaintiffs allege an arrangement whereby Anacleto agreed to buy the two parcels for ₱100,000.00, paid ₱30,000.00 initially, with a balance of ₱14,000.00. Plaintiffs were to regain possession upon full payment.
    • A separate covenant allegedly provided that defendants would return the lands upon plaintiffs’ payment. Plaintiffs demanded return but defendants refused despite barangay mediation, leading to court action.
  • Position of the Defendants
    • Defendants purchased lands directly from DBP by negotiated sale after foreclosure and redemption period lapsing, and deny they are bound by any return or repurchase agreement.
    • They assert they were misled by plaintiffs when signing the document agreeing to return the lands upon repayment, believing plaintiffs retained redemption rights.
  • Lower Court and Court of Appeals Decisions
    • The lower court declared the private writing (Exhibit C) an option to sell, not binding and validly withdrawn for want of consideration.
    • The sale contract (Exhibit C) and the contract of repurchase (Exhibit D) were declared void.
    • Plaintiffs ordered to return ₱30,000.00 with legal interest, restore possession to defendants, pay reasonable rent for two hectares while in possession, and bear costs.
    • The Court of Appeals affirmed the lower court decision.

Issues:

  • Whether the private writings (Exhibits C and D) evidencing the sale and repurchase agreement are valid and binding contracts.
  • Whether plaintiffs have the right to repurchase the properties from defendants after defendants' purchase from DBP.
  • Whether defendants are estopped from denying the validity of the contracts due to their prior acts of possession and tolerating plaintiffs’ cultivation.
  • Whether plaintiffs are justified in retaining the ₱30,000.00 advanced payment and not paying rent despite defendants’ demand for return of possession.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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