Case Summary (G.R. No. L-26768)
Applicable Law
The decision is primarily governed by the provisions of the Civil Code of the Philippines and relevant procedural rules outlined in the Rules of Court.
Factual Background
The case revolves around a Deed of Pacto de Retro Sale executed on May 26, 1951, whereby respondents Segundo Goyala and Antonina Almoguera sold a parcel of agricultural land to petitioner Faustino Gojo, with a provision for repurchase within one year. Following the sale, various claims emerged regarding the nature of the transaction, particularly whether it constituted a sale with a right to redeem or a disguised loan secured by a mortgage.
Proceedings in Trial Court
After the expiration of the one-year period for redemption, Faustino Gojo filed a petition on April 12, 1961, seeking consolidation of ownership over the property, asserting the right to ownership as the vendors failed to repurchase the land. In response, Segundo Goyala contested the claims, arguing that the transaction was essentially a mortgage rather than a sale, supported by tendering payment of the debt on the due date and asserting that petitioner refused to accept payment.
Dismissal of Appellant's Complaint and Default Declaration
On December 4, 1962, the trial court required petitioner to amend the complaint to substitute the deceased Antonina Almoguera with her heirs. Following his failure to do so, the trial court dismissed the complaint without prejudice on February 15, 1963. Subsequently, when Segundo Goyala moved to declare Gojo in default concerning the counterclaim, the trial court granted this motion, leading to a judgment favoring the respondents.
Decision on Counterclaim
The trial court ruled that the Deed of Pacto de Retro Sale was, in fact, an equitable mortgage. Observing that Goyala had tendered payment within the prescribed time, the court ordered Gojo to return the amount deposited in court and canceled the original deed, thus granting the respondents the right to redeem the property.
Appellant's Appeal
Faustino Gojo appealed the decision on several grounds, including the error in declaring him in default regarding the counterclaim, improper delegation to the Clerk of Court to receive evidence, and the correctness of the judgment allowing the redemption of the land.
Court's Reasoning
The appellate court found merit in Gojo's argument regarding the default declaration. It clarified that a plaintiff cannot be declared in default for failing to respond to a compulsory counterclaim, as the issues are intrinsically connected. Furtherm
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Case Background
- The case arises from an appeal by Faustino Gojo, the petitioner-appellant, from a decision by the Court of First Instance of Sorsogon regarding a counterclaim filed by the respondents, Segundo Goyala and Antonina Almoguera.
- The original complaint filed by Gojo was dismissed without prejudice due to his failure to submit an amended complaint as mandated by the court.
- The controversy centers on a "Deed of Pacto de Retro Sale" executed on May 26, 1951, wherein Goyala and Almoguera sold approximately 2.5 hectares of agricultural land to Gojo for P750.00, with a stipulation for repurchase within one year.
Facts of the Case
- On July 4, 1951, Gojo received an additional payment of P100.00 from the respondents.
- The respondents did not repurchase the land within the stipulated time, leading Gojo to file a petition for consolidation of ownership on April 12, 1961.
- Goyala opposed the petition, arguing that the transaction was a loan, not a sale, claiming that the Deed was a cover for a mortgage to secure a cash loan of P810.00.
- Goyala alleged that he attempted to repay the loan on the due date but was refused by Gojo.
Procedural History
- Goyala's opposition included a counterclaim requesting the dismissal of Gojo's petition, declaring the Deed a mortgage and seeking compensation for land use.
- The trial court required Gojo to a