Estelita Aguirre v. The Honorable Court of Appeals

Summary

The Supreme Court affirmed lower court decisions that a purported Deed of Absolute Sale of Boracay land was actually an equitable mortgage. Despite the contract's clear terms indicating sale, the Court applied Article 1602(6) of the Civil Code, finding the real intention was to secure debt payment. Key evidence included the vendors' continued possession through building structures and paying taxes, the vendee's eventual vacation of the property, and the lack of demands for vacation or rent. The decision emphasized that any single circumstance under Article 1602 suffices to establish an equitable mortgage, reflecting the law's preference for minimal transmission of property rights. The case demonstrates how courts examine parties' actual conduct and intention rather than merely contractual nomenclature in determining the true nature of agreements.