- Petitioner
- Raymundo M. Dapiton
- Respondent
- Court of Appeals
- Citation
- G.R. No. 107259
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Hermosisima, Jr., J.
- Decided
- June 9, 1997
Summary
This case involved a dispute over whether a 1967 deed of sale of property for P400 between Raymundo Dapiton and lawyer Meljohn dela Peña constituted an absolute sale or equitable mortgage. The deed contained annotations granting Dapiton one year to repurchase. When Dapiton attempted redemption in 1968, dela Peña rejected it claiming absolute ownership. The RTC and Court of Appeals ultimately favored dela Peña, but the Supreme Court reversed, applying Article 1602 of the Civil Code. The Court found multiple badges of equitable mortgage: inadequate price, vendor remaining in possession for 30 years, annotations contradicting absolute sale, and a pattern of similar secured transactions. The Court criticized dela Peña's conduct as a lawyer and ordered him to accept the redemption payment, establishing important precedent on equitable mortgage presumptions.