Case Digest (G.R. No. L-38745) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lucia Tan v. Arador Valdehueza and Rediculo Valdehueza (G.R. No. L-38745, August 6, 1975), plaintiff-appellee Lucia Tan filed Civil Case No. 2574 in the Court of First Instance of Misamis Occidental, Branch I, seeking (a) declaration of absolute ownership and recovery of possession of a parcel of land sold at a sheriff’s auction on May 6, 1955—she having been the highest bidder, obtained a Certificate of Sale, and, upon failure of defendant Arador Valdehueza to redeem within one year, received an Absolute Deed of Sale—and (b) consolidation of ownership of two portions of another unregistered parcel conveyed to her by defendants Arador and Rediculo Valdehueza in two separate deeds of pacto de retro (Annex D, dated August 5, 1955, unregistered; Annex E, dated March 15, 1955, registered) for a total consideration of ₱1,500, with the defendants retaining possession and paying realty taxes. Previously, in Civil Case No. 2002 (filed July 24, 1957), Tan had sought injunctive relief Case Digest (G.R. No. L-38745) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Plaintiff-Appellee: Lucia Tan. Defendants-Appellants: Arador and Rediculo Valdehueza (also joined by Pacita, Concepcion, Rosario Valdehueza).
- First Cause of Action:
- Parcel sold at public auction on May 6, 1955 in Oroquieta, Misamis Occidental; plaintiff was highest bidder.
- Certificate of Sale (Annex B) and, after failure to redeem within one year, Absolute Deed of Sale (Annex C) executed in plaintiff’s favor.
- Second Cause of Action:
- Two portions of unregistered land allegedly sold to plaintiff under Deeds of Pacto de Retro for P1,500 total.
- Annex D (dated August 5, 1955) unregistered; Annex E (dated March 15, 1955) registered.
- Procedural History and Stipulations
- Identity and capacity of parties admitted; defendants’ answer in Civil Case No. 2002 incorporated.
- Civil Case No. 2002 (filed July 24, 1957) for injunction against defendants entering and harvesting nuts was dismissed May 22, 1963 for failure to prosecute.
- Defendants remained in possession of the pacto de retro lands and paid realty taxes thereon.
- Parties submitted Annexes A–E as integral to the stipulation of facts.
Issues:
- Whether the dismissal of Civil Case No. 2002 operates as res judicata to bar the first cause of action in Civil Case No. 2574.
- Whether the transactions under the two Deeds of Pacto de Retro are simple loans or constitute equitable mortgages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)