Dorado v. Viriña
REITERATIONFacts
The Antecedents: Plaintiffs Felipe Dorado and Antonia Vista sold three parcels of coconut land to defendants Agripino Viriña and Petra Cuento on February 3, 1902, under a right of repurchase for P100, with no stipulated redemption period. The vendors retained possession as usufructuaries, paying a quarterly rent of P15, which was later increased to P22.50 after an additional P50 payment. The contract stipulated that failure to pay rent would authorize the purchasers to take possession. Procedural History: On September 9, 1904, Agripino Viriña filed a complaint for forcible entry and detainer against Felipe Dorado in the justice of the peace court of Nagcarlan, alleging non-payment of rent since March 25, 1903. Felipe Dorado acknowledged the debt for rent but claimed inability to pay. The justice of the peace rendered judgment for ejectment and payment of P174 in rent. The judgment was executed on October 11, 1904, placing Viriña in possession. The Petition: Felipe Dorado and Antonia Vista filed suit in the Court of First Instance, seeking to nullify the justice of the peace court's judgment and recover possession of the lands, alleging lack of jurisdiction and bad faith on the part of the defendants. The Court of First Instance declared the justice of the peace proceedings null and void, found the defendants in bad faith from October 11, 1904, to February 3, 1906, and ordered them to pay P1,666 for unlawfully collected fruits.
Issue(s)
Whether the plaintiffs still have the right to demand restitution of the lands sold under right of repurchase. Whether the judgment rendered by the justice of the peace of Nagcarlan on September 13, 1904, is null and void due to lack of jurisdiction. Whether the possession of the defendants is legal or illegal.
Ruling
The Supreme Court decreed that the defendants are not obliged to restore the lands to the plaintiffs, and both the defendants and Vivencio Zulaibar are absolved from the complaint. The judgment of the Court of First Instance is affirmed in part and reversed in part.
Ratio Decidendi
On the right to restitution of the lands: The Court held that the plaintiffs have no right to demand restitution because the period for redemption, governed by Article 1508 of the Civil Code in the absence of a stipulated term, expired on February 3, 1906. Since no repurchase was made by February 3, 1906, the ownership of the defendants consolidated and the sale became irrevocable and absolute. The plaintiffs failed to prove any attempt to repurchase the lands from February 3, 1902, to June 10, 1913, the date of filing the action. On the nullity of the justice of the peace judgment: The Court found that the justice of the peace acted within his jurisdiction. The complaint for detainer was filed on September 9, 1904, within one year from the repeated demands for rent made by Agripino Viriña from Lent (February-April) 1904. The defendant Felipe Dorado, by personally appearing and acknowledging the debt without demurring or objecting to the complaint, and by failing to appeal the judgment, is estopped from challenging its legality. The justice of the peace's judgment did not prejudice Dorado's right to redeem the lands within the four-year period. On the legality of the defendants' possession: The Court ruled that the defendants' possession, obtained through a valid execution of the justice of the peace's judgment, was legal. The plaintiffs violated the contract by failing to pay rent, which, according to the contract, authorized the purchasers to take possession. The plaintiffs, as lessees who failed to pay rent and retained the fruits, cannot enrich themselves at the expense of the owners. Therefore, the defendants were not in bad faith from October 11, 1904, to February 3, 1906, and the award of P1,666 for fruits was reversed.
Main Doctrine
The failure to repurchase property sold under a right of repurchase within the statutory period, or the agreed period if shorter, results in the consolidation of ownership in the vendee. A judgment of ejectment rendered by a justice of the peace court, within its jurisdiction and after proper demand and hearing, is valid and can be executed, even if the underlying contract is later challenged, provided the challenge is not timely or properly raised.