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Case Digest: Antonio Jayme, et.al. vs Hon. Nestor Alampay, G.R. No. L-39592

Antonio Jayme, et.al. vs Hon. Nestor Alampay, GR No. L-39592, January 28, 1975

Subject: Obligations and Contracts

FACTS

Antonio Jayme and Ana Solidarios spouses signed mortgage contract with Benito Ong, and they also signed a deed of sale. Petitioner spouse filed a complaint in the court of first instance of Negros Occidental presided by respondent judge on November 29, 1972 for the reformation of instrument, praying that the deed of sale of the parcel of land in Bacolod executed by them on December 24, 1964 in favor of Benito Ong, which did not embody their true agreement be reformed and declared a contract of mortgage, and that their property be returned to them upon their paternity be reformed and declared a contract of mortgage. The petitioners claim that they entered into an agreement.

ISSUE

Whether or not the respondent court manifestly erred in holding that petitioners' action prescribed four years after the execution of the questioned deed of sale on the premise of its unsupported prejudgment in its dismissal order.

RULING

Yes, respondent court manifestly erred in holding that petitioners' action prescribed four years after the execution of the questioned deed of sale on the premise of its unsupported prejudgment in its dismissal order.

Under the law (Article 1368, NCC), reformation may be ordered at the instance of either party or his successor in interest, if the mistake was mutual; otherwise, upon petition of the injured party, or his heirs and assigns.

The period of prescription for the reformation of a contract (such as one ostensibly an absolute sale but actually a mortgage) is ten years.

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