Case Summary (G.R. No. 165907)
Key Dates
- 25 August 1979: Rose Alciso sells with right to repurchase to Jaime Sansano.
- 28 March 1980: Alciso sells the same parcel to Celso Bate.
- 14 August 1981: Bate sells to Spouses Narvaez, carrying over Alciso’s right to repurchase under conditions imposed by the Narvaez.
- 15 June 1984: Alciso files suit to annul the successive deeds and enforce her right to repurchase.
- 6 April 1998: RTC renders decision in favor of Alciso’s right to buy back.
- 29 October 2004: Court of Appeals affirms with modification and orders determination of a reasonable repurchase price.
- 27 July 2009: Supreme Court issues final decision.
Applicable Law
- 1987 Philippine Constitution (post-1990 decisions).
- Civil Code provisions on:
• Stipulation pour autrui (Art. 1311[2] and jurisprudential requisites)
• Conventional redemption or sale with right to repurchase (Arts. 1601, 1606, 1616)
• Rights of builders in good faith (Art. 448)
Facts
Larry Ogas initially owned the 1,329 m² parcel under TCT No. T-1068. He sold it to his daughter, Rose Alciso (TCT No. T-12422). Alciso sold with right to repurchase to Sansano (P10,000), reacquired it, then sold it to Bate for P50,000 (TCT No. T-16066). Bate sold to Spouses Narvaez for P80,000, incorporating Alciso’s right to repurchase “at a price under such conditions as the present buyers may impose.” The Narvaez constructed a P300,000 commercial building. Alciso sought to exercise her repurchase right but disagreed on price (Narvaez demanded P300,000; Alciso offered P150,000).
Regional Trial Court Ruling
The RTC held that:
- Alciso’s earlier rights under the 1979 deed were extinguished upon her repurchase from Sansano.
- The claim to annul the 1980 sale was time-barred.
- Alciso lacked personality to annul the 1981 deed but could enforce the stipulation pour autrui therein.
- Alciso effectively communicated acceptance of that stipulation; repurchase price fixed at P80,000.
- Alciso could either appropriate the building upon indemnity payment or compel sale of the land.
- Alciso was entitled to attorney’s fees and nominal damages.
Court of Appeals Ruling
The appellate court affirmed the existence of a stipulation pour autrui and Alciso’s acceptance but modified the repurchase price issue, remanding to the RTC to determine a reasonable price. It characterized the contract as a sale with right of repurchase, not a mortgage, and recognized the Narvaez as builders in good faith governed by Civil Code Article 448.
Issue
Whether Alciso validly communicated her acceptance of the stipulation pour autrui in the 14 August 1981 deed, thereby preserving her right to repurchase.
Supreme Court Analysis on Stipulation Pour Autrui
- Requisites (Limitless Potentials, Inc. v. Quilala): (1) stipulation for a third person; (2) part of a larger contract; (3) deliberate conferment of favor; (4) unconditional and uncompensated; (5) acceptance communicated before revocation; (6) no representation of the third party by contracting parties.
- The communication of acceptance is a factual matter; the RTC’s finding that Alciso informed the Narvaez of her intent to redeem is binding, absent any exception.
Supreme Court Analysis on Applicable Redemption Remedies
- Article 448 is inapplicable, as that governs improvements by non-owners; here, the Narvaez were owners when they built.
- The transaction is a sale with r
Case Syllabus (G.R. No. 165907)
Facts
- Larry A. Ogas owned a 1,329-sqm parcel in Pico, La Trinidad, Benguet, covered by TCT No. T-1068, partly leased to Esso Standard Eastern, Inc.
- Ogas sold the property to his daughter Rose O. Alciso; TCT No. T-1068 was cancelled and TCT No. T-12422 issued in Alciso’s name.
- On 25 August 1979, Alciso executed a Deed of Sale with Right to Repurchase in favor of Jaime Sansano for ₱10,000; she later exercised the right and repurchased the land.
- On 28 March 1980, Alciso sold the same parcel to Celso S. Bate for ₱50,000 by Deed of Absolute Sale, warranting freedom from liens except the Esso lease; TCT No. T-12422 was replaced by TCT No. T-16066.
- On 14 August 1981, Bate sold to Spouses Dominador R. Narvaez and Lilia W. Narvaez for ₱80,000 by Deed of Sale of Realty; TCT No. T-16066 was cancelled and TCT No. T-16528 issued.
- In 1982, the Narvaez spouses constructed a commercial building worth ₱300,000 on the land.
- Alciso demanded inclusion of a stipulation allowing her to repurchase the property under conditions imposed by the Narvaez spouses; the Deed of 14 August 1981 carried that stipulation pour autrui.
- Alciso purportedly informed the Narvaez spouses of her desire to repurchase; negotiations failed when the spouses asked ₱300,000 and Alciso offered ₱150,000.
- On 15 June 1984, Alciso filed a complaint in the RTC seeking annulment of the three deeds, cancellation of TCT Nos. T-16066 and T-16528, reconveyance, damages, and attorney’s fees, alleging the true agreement was a real‐estate mortgage.
Procedural History
- The Regional Trial Court of La Trinidad, Benguet (Branch 8) rendered its Decision on 6 April 1998.
- The Narvaez spouses appealed to the Court of Appeals in CA-G.R. CV No. 63757; the appellate court issued its Decision on 29 October 2004, affirming with modifications and remanding for repurchase‐price determination.
- The Narvaez spouses filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court on 15 December 2004, challenging factual findings on acceptance of the stipulation pour autrui.
Issue
- Whether Rose O. Alciso communicated her acceptance of the stipulation pour autrui in the 14 August 1981 Deed of Sale of Realty