Case Summary (G.R. No. L-22012)
Factual Background
The respondents initiated Civil Case No. 3066 in the Court of First Instance of Oriental Negros against the petitioners, asserting that the Quijanos (vendors a retro) had failed to exercise their right to repurchase the two parcels of land within the agreed period. The petitioners countered by characterizing the transaction as a disguised equitable mortgage, alleging that the deed was merely a cover for a usurious loan.
Compromise Agreement
Before the trial commenced, the parties reached a Compromise Agreement dated February 7, 1956, which was submitted to the court for approval on February 9, 1956. The agreement stipulated a timeline for the repurchase, granting the defendants eight months to repurchase the two parcels of land for PHP 8,527.00, with all related expenses to be borne by the defendants. The parties confirmed the properties as belonging to Otilla Sevilla, recorded in a deed of sale with a right of repurchase.
Tender of Payment and Court Orders
On October 9, 1956, the defendants deposited PHP 7,670.00 and later delivered the remaining amount required to complete the repurchase price. However, the plaintiffs refused to accept the payment, asserting that the repurchase period had lapsed. Subsequently, the defendants filed for a motion to confirm the repurchase, which was granted by the lower court on February 27, 1957, ordering the plaintiffs to reconvey the property to the defendants.
Appeal and Court of Appeals Decision
The plaintiffs appealed the order to the Court of Appeals, which ruled on August 28, 1963, to set aside the lower court's order. The appellate court concluded that the defendants had failed to repurchase the property within the stipulated time frame and affirmed the plaintiffs as the absolute owners of the parcels of land.
Legal Issues
The core issue was whether the defendants made the repurchase within the stipulated eight-month period. The compromise agreement itself stated that this period began with the execution date of the agreement and not the judgment.
Supreme Court Findings
The Supreme Court acknowledged that the date for the commencement of the eight-month period was indeed February 7, 1956, while the payment was made on October 9, 1956, leading to a technical expiration of the period. Nonetheless, the Court found that the petitioners acted in good faith, genuinely believing that the timeline was tie
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Case Overview
- The case involves the spouses Nicolas Quinanola and Eustaquia Tabio (respondents) initiating Civil Case No. 3066 in the Court of First Instance of Oriental Negros against the spouses Florencio Quijano and Leonor Sevilla, along with Otilla Sevilla (petitioners).
- The core issue revolves around the ownership of two parcels of land, which were subject to a deed of pacto de retro sale executed in favor of the respondents.
- The plaintiffs, Quinanola and Tabio, claimed that the vendors (Quijano and Sevilla) failed to exercise their right to repurchase the properties within the agreed period.
Background of the Case
- The defendants (Quijano and Sevilla) countered that the transaction was not a proper sale but rather an equitable mortgage, alleging it was a cover for a usurious loan.
- Prior to the trial, the parties reached a Compromise Agreement on February 7, 1956, which was submitted to the court on February 9, 1956.
Compromise Agreement
- The agreement stipulated the following key terms:
- The plaintiffs granted the defendants a period of eight (8) months to repurchase the two parcels of land for a total price of ₱8,527.00.
- All expenses related to the repurchase were to be borne by the defendants.
- Should the defendants fail to repurchase within the stipulated period, the plaintiffs would become the absolute owners of the land.
- The defendants agreed to dismiss their counterclaim against the plaintiffs.
- The properties in question were confirmed as the paraphernal property of Otilla Sevilla.
Events Following the Compromise Agreement
- On October 9, 1956, the defendants deposited ₱7,670.00 with the Clerk of Court and remitted the remaining ₱857.00 required to complete the repurchase price on th