Title
Albert vs. Punsalan
Case
G.R. No. L-3190
Decision Date
Dec 4, 1907
Petitioners claimed land ownership via unregistered purchase; respondents opposed, citing pacto de retro. Court ruled for petitioners, affirming ownership due to expired redemption period.

Case Summary (G.R. No. L-3190)

Petitioner's Claim

The petitioners assert their ownership of the land by claiming to have purchased it from several individuals, including Narciso Mayuga y Bautista and others. They base their petition on a purchase document attached to their filing; however, this document was not officially registered, which becomes pivotal in the court's consideration of the validity of their claim.

Respondents' Opposition

The respondents counter the petitioner's claim by asserting that the property originally belonged to Julian Punsalan, who secured it under a "pacto de retro" mortgage to Teodorico Bautista. They contend that they are the heirs of Julian Punsalan, and at no time did he or they convey ownership of the property to the petitioners. The respondents maintain that they have continuously expressed their willingness to redeem the property from the mortgage arrangement.

Lower Court Proceedings

On January 3, 1906, the Court of Land Registration rendered a decision favoring the petitioners. The court found that the petitioners acquired the land legally through purchase from the heirs of the original owner. It was determined that the delivery of the property occurred in 1879 along with a monetary transaction of 130 pesos. The lower court also cited the historical context of the ownership and the legal documentation associated with the sale.

Legal Basis of the Dispute

The crux of the legal argument rested on whether the agreement between Julian Punsalan and Teodorico Bautista constituted a valid pacto de retro. The court examined the stipulated conditions in the original contract, affirming that since the vendors (Punsalan's heirs) did not redeem the land within the statutory time frame prescribed by the Civil Code, the petitioners ultimately secured absolute ownership.

Applicable Provisions of the Civil Code

The court referenced pertinent articles of the Civil Code, specifically Article 1508, dictating that in the absence of an express agreement, the right of redemption lasts for four years and can extend up to ten years if so stipulated. Article 1518 further clarifies the conditions under which the vendor must operate to regain

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