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. ...

Facts:

Parties Involved:

• Plaintiffs and Appellees: Juan Verceluz et al.
• Defendants and Appellants: Deogracias Edano et al.

Subject Matter: The plaintiffs sought to annul a deed of sale for a certain land or, if deemed valid, to have it rescinded. They also demanded the return of the land and its fruits received since the filing of the complaint, with a reservation to file a criminal action against the defendants.

Background:

• On October 11, 1914, the plaintiffs executed a public document selling the land to the defendants.
• The defendants claimed they had been in peaceful possession of the land since the sale and that the plaintiffs never questioned the validity of the deed.
• The plaintiffs later alleged fraud and sought rescission of the sale, claiming the purchase price was never paid.

Key Events:

• The defendants argued that the plaintiffs ratified the sale on April 6, 1916, and that the action for annulment had prescribed after four years.
• The trial court ruled in favor of the plaintiffs, decreeing the rescission of the sale and ordering the defendants to return the land and account for its fruits.

Defendants' Appeal: The defendants appealed, assigning seven errors, primarily contesting the trial court's findings on the payment of the purchase price, the credibility of witnesses, and the rescission of the sale.

Issue:

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Ruling:

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Ratio:

1. Burden of Proof:

   • The defendants, as the parties claiming payment, bore the burden of proving that the purchase price was paid. They failed to provide sufficient evidence to support their claim.

2. Rescission of Contract:

   • Under Articles 1506 and 1124 of the Civil Code, the plaintiffs, as vendors, had the right to demand either payment of the price or rescission of the contract due to the defendants' breach.

3. Return of Fruits:

   • Article 1295 of the Civil Code requires the return of the land and its fruits upon rescission, retroactive to the filing of the complaint.

4. Credibility of Witnesses:

   • The trial court's assessment of witness credibility was upheld, as the rule falsus in uno, falsus in omnibus is not absolute.

5. Good Faith Possession:

   • The defendants' possession was not in good faith, as they failed to pay the purchase price, a fundamental obligation under the contract.

6. Prescription and Estoppel:

   • The plaintiffs' action was not barred by prescription or estoppel, as the defendants failed to establish these defenses conclusively.