Case Digest (G.R. No. L-22012)
Facts:
The case involves a dispute between petitioners Otilla Sevilla, Florencio Quijano, and Leonor Sevilla, and respondents Nicolas Quinanola and Eustaquia Tabio. The controversy arose from Civil Case No. 3066 in the Court of First Instance of Oriental Negros. On February 7, 1956, the respondents filed a complaint alleging that the petitioners failed to exercise their right to repurchase two parcels of land sold under a deed of pacto de retro sale. In their defense, the petitioners contended that the transaction was not a true sale but a mere equitable mortgage, intended to mask a usurious loan. Before trial, the parties entered into a Compromise Agreement, which was submitted to the Court on February 9, 1956. This agreement stipulated an eight-month period from the date to repurchase the properties for P8,527.00, with certain conditions concerning expenses and ownership transfer in the event of non-repurchase.
On October 9, 1956, exactly eight months after the court’s judgment, th
Case Digest (G.R. No. L-22012)
Facts:
Petitioners Florencio Quijano, Leonor Sevilla, and Otilla Sevilla sold two parcels of land subject to a pacto de retro sale to respondents Nicolas Quinanola and Eustaquia Tabio. The parties entered into a Compromise Agreement on February 7, 1956, which provided that the respondents could repurchase the land within a period of eight (8) months by paying a total of P8,527.00. The terms further stipulated that, upon the failure of the respondents to repurchase within the prescribed period, the plaintiffs would retain absolute ownership of the property. On October 9, 1956—exactly eight months from the date the court rendered a judgment on the compromise—the respondents tendered the payment through a deposit and money order, albeit two days after the execution date of the agreement itself. The plaintiffs refused to accept the payment and reconvey the land, arguing that the repurchase period had expired. The lower court, upon hearing a motion by the respondents for confirmation of the repurchase, ordered the plaintiffs to reconvey the property. However, the Court of Appeals reversed that order, declaring the plaintiffs the absolute owners because the repurchase was not effected “on time.” The present case brings into question the timeliness of the repurchase payment and whether the respondents had substantially performed their obligation.Issues:
- Whether the respondents’ repayment, tendered on October 9, 1956, was made within the agreed eight-month period despite the two-day discrepancy between the execution of the compromise agreement (February 7, 1956) and the judgment date (February 9, 1956).
- Whether the respondents’ performance, though technically delayed by two days, constitutes a strict and complete fulfillment of their obligation under the Compromise Agreement, considering the good faith in which they acted.
- The applicability of Article 1234 of the New Civil Code in deeming the performance sufficient despite the minor technical lapse.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)