J.R. Blanco v. William H. Quasha

Summary

This case involves a dispute over the validity of a sale-lease-back agreement between American national Mary Ruth Elizalde and Parex Realty Corporation. In 1975, Elizalde sold her Forbes Park property to Parex for P625,000 payable in 25 annual installments, while simultaneously leasing it back for 25 years at matching annual rental payments. After Elizalde's death in 1990, her estate administrator claimed the transaction was simulated to circumvent foreign ownership restrictions following the Republic v. Quasha decision. The Regional Trial Court found the sale fictitious and ordered reconveyance, but the Court of Appeals reversed, finding the sale valid based on compliance with Civil Code requirements and evidence of genuine intent to transfer ownership. The Supreme Court affirmed, holding that the determination of simulation involves factual questions beyond its review and that the appellate court's findings were supported by substantial evidence. The decision establishes that sale-lease-back arrangements are valid when parties genuinely intend to be bound and all legal requirements are met.