Sunday, July 9, 2023

Case Digest: Aquino vs Deala, 63 Phil 582

Aquino vs Deala, 63 Phil 582

Subject: Obligations and Contracts

FACTS

The defendant approached Mariano Aquino, the plaintiff’s father, to solicit a loan for a certain amount secured by the real property, on which a house of strong materials was built. Mariano Aquino acceded to the defendant’s proposition on condition that the transaction be evidenced by a deed in the form and under the conditions imposed because otherwise he would not have obtained the sum needed by him.

The deed was novated on December 26, 1926, the only alteration made being in the clause referring to the price and the rent which were increased to P4,500 and P45, respectively. It was renovated on May 31, 1927, by increasing said price and rent to P5,200 and P52, respectively. On April 20, 1931, it was finally renovated by increasing the price to P6,600, reducing the rent to P49.50 a month and extending the period of repurchase to April 20, 1933, the original period of four years agreed upon having expired some months before. Except for the amount of the price and the rent and the extension of the period of repurchase, the stipulations of the original deed were left intact in the subsequent novation.

On November 4, 1926, the defendant obtained permission from the department of engineering and public works to construct a two-story house of strong materials on the vacant part of the lot in question, the work having been finished about June 23, 1928.

On June 9, 1933, Mariano Aquino had the consolidation of his ownership of the property referred to in said documents registered in the registry of deeds and transfer certificate of title was issued to him. He died sometime later and his son Antonio F. Aquino, who instituted the present ejectment proceedings in the municipal court of Manila, was appointed special administrator of his testate estate. The defendant timely raised the question of ownership both in the court of origin and in the Court of First Instance. The municipal court ordered the defendant to vacate the property in question and to pay the plaintiff the unpaid rents at the rate of P50 a month, plus the costs. The Court of First Instance, on appeal, substantially affirmed the appealed judgment, overruling the defenses set up by the defendant.

ISSUE

Whether or not the contract is really a sale with the right of repurchase (pacto de retro) or is it really a mortgage (an equitable mortgage).

RULING

No, it is not a “sale with right of repurchase” as it deemed be but actually an equitable mortgage in disguise.

Under the law (Article 1370 par.1, NCC), if the terms of a contract are clear and leave no doubt upon the intention of the contracting parties, the literal meaning of its stipulations shall control.

Although apparently this is a pacto de retro, it really is an equitable mortgage, for considering the circumstances of the case, the purpose of the contract was really to make the house the security for the loan. There was no real intention here to sell the house.

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