Narcisa Avila v. Spouses Benjamin Barabat

Summary

The Supreme Court affirmed lower courts' ruling that a 1979 private document between Narcisa Avila and spouses Barabat constituted a valid sale of property, not an equitable mortgage. The Court rejected petitioners' arguments under Civil Code Articles 1602 and 1604, finding that the circumstances did not establish an equitable mortgage. Critically, the Court held that Avila's siblings had no redemption rights under Articles 1620 and 1623 because co-ownership of the inherited property had been extinguished by prior partition - the siblings had already physically segregated and possessed their respective shares. The decision validated the Barabats' ownership and rejected claims of gross inadequacy of consideration, emphasizing that factual findings of trial courts confirmed by appellate courts are binding on the Supreme Court.