Case Digest (G.R. No. 21284)
Facts:
- The case involves Juan Verceluz et al. vs. Deogracias Edano et al..
- Plaintiffs filed an action to annul a deed of sale for a parcel of land on March 12, 1924.
- They sought to declare the deed invalid or, if valid, to rescind it and recover the land and its fruits since the complaint was filed.
- Plaintiffs reserved the right to pursue criminal charges and sought costs for the suit.
- Defendants denied the allegations, claiming the plaintiffs sold the land through a public document dated October 11, 1914.
- Defendants asserted they possessed the land peacefully and continuously, with the plaintiffs' acquiescence.
- They argued that the plaintiffs acknowledged the sale in an official document on April 6, 1916, and were estopped from contesting the sale due to inaction over four years.
- The lower court ruled in favor of the plaintiffs, ordering rescission of the sale and return of the land and its fruits.
- Defendants appealed, citing errors regarding payment, witness credibility, and possession.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the lower court's decision in all respects.
- The court ruled that the defendants failed to prove the payment of the purchase price, making the sale subject to rescission.
- Defendants were not in good faith possession o...(Unlock)
Ratio:
- The court's decision hinged on the defendants' inability to prove that the purchase price of ₱3,000 was paid.
- Defendants admitted the price was not paid at the deed's execution, and their claims of subsequent payment lacked sufficient evidence.
- The burden of proof rested on the defendants to show that payment occurred post-execution, which they did not fulfill.
- The plaintiffs' testimony, corroborated by other witnesses, was credible and indicated that the price had not been paid.
- The principle of falsus in uno, falsus in omnibus was not...continue reading
Case Digest (G.R. No. 21284)
Facts:
In the case of Juan Verceluz et al. vs. Deogracias Edano et al., the plaintiffs, Juan Verceluz and others, initiated an action to annul a deed of sale concerning a parcel of land. The case was filed on March 12, 1924, and the events leading to the lawsuit took place in the Philippines. The plaintiffs sought to either declare the deed of sale invalid or, if deemed valid, to rescind it and compel the defendants to return the land along with any fruits derived from it since the filing of the complaint. The plaintiffs also reserved the right to pursue criminal charges against the defendants, Deogracias Edano and Nicolas T. Zamora, and sought costs for the suit.
In response, the defendants denied the allegations and asserted a special defense, claiming that the plaintiffs had sold the land to them through a public document dated October 11, 1914. They argued that they had possessed the land peacefully and continuously since the sale, with the plaintiffs' acquiescence. The defendants contended that the plaintiffs had acknowledged the sale in an official document on April 6, 1916, and that the plaintiffs were estopped from contesting the sale due to their inaction over a four-year period, which they claimed had led to the prescription of the action.
After trial, the lower court ruled in favor of the plaintiffs, ordering the rescission of the sale and requiring the defendants to return the land and account for the fruits received since the filing of the complaint. The defendants appealed the decision, raising several errors regarding the court's findings on the payment of the sale price, the credibility of witness testimonies, and the good faith possession of the land.
Issue:
- Was the stipulated price of ₱3,000 paid by the defendants to the...