Case Summary (G.R. No. 170351)
Facts of the Case
The original homestead, covered by Homestead Patent No. 3887 issued on June 7, 1922, was later the subject of a conditional sale executed by Simeon Patalinghud in favor of Felisa Ballesteros on April 27, 1959. The deed stipulated a sale of a portion of land measuring one-half hectare and provided details about the payment schedule and expenses related to the segregation of said land. Following full payment and proper survey, a subsequent absolute sale was executed on November 7, 1960, which was duly registered.
Dispute Over Repurchase Rights
On June 23, 1964, Simeon Patalinghud attempted to repurchase the land, claiming his right under Section 119 of Commonwealth Act 141, which allows a homesteader or their heirs to reclaim the property sold within five years from the date of sale. Felisa Ballesteros rejected the offer, arguing that the five-year repurchase period had expired, as the initial conditional sale was executed on April 27, 1959.
Court Proceedings
After the trial court dismissed Patalinghud's complaint, he appealed, asserting that the repurchase period should have commenced from the later date of November 7, 1960, when the absolute sale was executed. He contended that the conditional sale did not constitute a complete transfer of title since it lacked a specific description of the land sold.
Ruling on Repurchase Period
The court held that the five-year period for repurchase must be counted from the date of the initial conditional sale. It found that the deed of conditional sale represented a perfected contract of sale. The court stated that the terms of the deed related solely to the manner of payment and segregation of the land and did not impact its validity. The established ruling emphasized that "conveyance" under the law encompasses all types of property transfers, confirming that the conditional sale executed constituted a valid transfer.
Interpretation of Conveyance
The court noted that the conditional sale included a specific description of the land and that the conditions stated did not hinder the transfer of ownership. The reasoned view revealed that a conveyance takes effect at the time of execution, irrespective of subsequent registration. Co
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Case Overview
- Court: Supreme Court of the Philippines
- Citation: 148 Phil. 252
- G.R. No.: L-25421
- Date of Decision: March 31, 1971
- Parties: Simeon Patalinghud (Plaintiff-Appellant) vs. Felisa Ballesteros (Defendant-Appellee)
- Nature of Case: Appeal from the decision of the Court of First Instance of Davao dismissing the complaint in Civil Case No. 4356.
Factual Background
- Plaintiff, Simeon Patalinghud, is an heir of Jose Patalinghud, the original homesteader of a parcel of land in Dumoy, Davao City, covered by Homestead Patent No. 3887 issued on June 7, 1922.
- On April 27, 1959, Patalinghud executed a "Deed of Conditional Sale" in favor of Felisa Ballesteros concerning a portion of one-half hectare of the homestead land.
- The deed detailed terms of payment and indicated that the vendee would bear the expenses for segregating the land after the harvest of crops.
- On November 7, 1960, after full payment was made, Patalinghud executed an "Absolute Sale of Land," transferring ownership of Lot 344-B-2-B-5 to Ballesteros, which was registered, resulting in the issuance of Transfer Certificate of Title No. T-9409.
- On June 23, 1964, Patalinghud offered to repurchase the lot for P700, claiming the right to do so under the law within five years of the conveyance.
- Ballesteros refused the offer, leading Patalinghud to file a complaint