Delfin v. Dellota
REITERATIONFacts
The Antecedents: Dionisia Dorado Delfin was the registered owner of Lot No. 1213. She executed an "Escritura De Venta Con Pacto de Retro" over a 50,000-square meter portion in favor of spouses Ildefonso Dellota and Patricia Delfin. Subsequently, she sold another 50,000-square meter portion of the same lot to Gumersindo Deleña via a notarized "Deed of Sale with Right of Redemption." Dionisia failed to exercise her right of redemption for this portion. Salvador Dellota leased this area from Gumersindo. Later, Dionisia executed a "Deed of Mortgage and Promise To Sell" in favor of Salvador over a 90,000-square meter portion of Lot No. 1213. Procedural History: Dionisia filed a complaint for recovery of possession and damages against Salvador Dellota. Gumersindo filed a motion for intervention. The trial court ordered Salvador's wife to allow redemption of a 40,000-square meter portion upon payment, declared ownership of the 50,000-square meter portion consolidated in Gumersindo's heirs, and ordered Dionisia to pay costs. The Court of Appeals affirmed the trial court's decision. The Petition: Dionisia's heirs contend that the "Deed of Sale with Right of Redemption" executed with Gumersindo is an equitable mortgage due to the alleged unusual inadequacy of the price (P5,300.00 for five hectares).
Issue(s)
Whether the "Deed of Sale with Right of Redemption" dated June 9, 1949, is an equitable mortgage under Article 1602 of the Civil Code due to alleged unusual inadequacy of price. Whether the payment of realty taxes by Dionisia is conclusive evidence of her ownership.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of equitable mortgage: The Court held that the price agreed upon in a pacto de retro sale is not generally considered the just value of the thing sold, absent other corroborative evidence. Following jurisprudence, there is no requirement that the price be equal to the exact value of the subject matter. The Court found no cogent reason to conclude that the P5,300.00 price for the five-hectare portion in 1949 was unreasonable or unusually inadequate. Furthermore, the Court reiterated that it is presumed that a person takes ordinary care of his concerns, and there was no evidence that Dionisia did not understand the contract or was forced into it. Courts are not guardians of parties who are not legally incompetent and will not extricate them from a bad bargain. The Court also noted that Dionisia failed to prove the alleged gross inadequacy of the price before the trial court. On the issue of realty taxes: The Court affirmed the Court of Appeals' finding that tax receipts per se are not conclusive evidence of land ownership absent other corroborative evidence. The timing of Dionisia's payment of realty taxes for the period 1955 to 1963, made only in December 1963, shortly before filing the complaint in June 1964, raised questions and led to the inescapable conclusion that such payment was made in preparation for the lawsuit.
Main Doctrine
The price agreed upon in a pacto de retro sale is not necessarily the just value of the thing sold, and courts will not extricate a party from a bad bargain absent proof of fraud, force, or undue influence. Tax receipts alone are not conclusive evidence of ownership.