Barceliza P. Capistrano v. Darryl Limcuando

Summary

The Supreme Court denied petitioner's action to annul a deed of sale or exercise repurchase rights under the Public Land Act. Petitioner sold the same property twice - first to spouses Zuasola and Subida in 1985 with right of repurchase, then half of it to respondents in 1989. When respondents defaulted on payments, petitioner sought to annul the second sale or repurchase the property. The Court applied the clean hands doctrine under Article 1397 of the Civil Code, ruling that petitioner cannot seek annulment based on fraud she herself committed through the double sale. The Court also held that petitioner's right to repurchase under the Public Land Act should be denied as her profit-making motive through successive conveyances contradicted the law's noble intent to preserve family homesteads. The decision upheld the validity of the deed of sale but ordered respondents to pay the P65,000.00 balance of the purchase price.