Sunday, July 9, 2023

Case Digest: Ong Chua vs Carr, et.al., 53 Phil 975

Ong Chua vs Carr, et.al., 53 Phil 975

Subject: Obligations and Contracts

FACTS

Henry Teck sold his land to Ong Chua with the right to repurchase within four years. Ong sold the land to Edward Carr with the understanding that Edward Carr was buying it, subject to the right to repurchase on the part of Teck. At that time, Carr did not have enough money. So Edward Carr asked for a loan from an Association.

Association offered to give a loan provided Carr could offer, as security, land of which he was absolute owner, that is, land which would not be subject for example to repurchase. So Carr began to thing. With the help of a lawyer who drafter the deed, Carr and Ong (who did not know English) signed a contract with Carr was made out to be the absolute owner of the land and the words regarding the “right to repurchase” omitted.

Later Tek was repurchasing the property from Ong, and Ong demanded the reconveyance of the property from Carr. Carr refused on the ground that he (Carr) was the absolute owner of the land. Hence, Ong brought this action against Carr.

ISSUE

Whether or not the contract may be reformed. If so, may Ong now demand the land from Carr so that it would be resold to Tek.

RULING

Yes, the contract may be reformed.

Under the law (Art 1362, NCC), if one party was mistaken and the other acted fraudulently or inequitably in such a way that the instrument does not show their true intention, the former may ask for the reformation of the instrument.

In this case, it follows, therefore, that Ong may now demand the reconveyance of the property to him so that the land may be repurchased by Tek. 

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