Luz Ardena Salame v. Court of Appeals

Summary

Heirs of Vicenta Acevedo sought reconveyance of a 1/2 share of agricultural land, claiming three separate property transactions constituted a single equitable mortgage under Civil Code Articles 1602 and 1604. The transactions involved a 1962 conditional sale with repurchase rights, a 1964 absolute sale, and a 1967 promise to sell back. The Supreme Court rejected this claim, holding that the three notarized documents were separate independent transactions with presumption of regularity. The Court applied the Parol Evidence Rule, finding the documents clear and unambiguous. The Promise to Sell was deemed unenforceable under Article 1479 for lacking price certainty and distinct consideration. The decision affirmed that the absolute sale terminated any repurchase rights, making the subsequent promise a separate transaction that failed legal requirements for validity.