Petitioner
Adoracion Redondo
Respondent
Angelina Jimenez
Citation
G.R. No. 161479
Court
Supreme Court
Division
Second Division
Ponente
Quisumbing, J.
Decided
October 18, 2007

Summary

Adoracion Redondo challenged the validity of a 1981 sale of her share in family property to her sister-in-law Angelina Jimenez, claiming it was an equitable mortgage and that her consent was obtained through fraud. The Supreme Court affirmed lower courts' dismissal, ruling the transaction was a valid absolute sale. The P3,000 consideration was reasonable given the property's P5,640 market value for Adoracion's share and her financial distress. Key factors supporting the sale included Angelina's payment of realty taxes and absence of circumstances indicating equitable mortgage under Article 1602 of the Civil Code. Even if fraud existed, Adoracion's action was time-barred, having been filed four years and four months after the deed's registration, exceeding the four-year prescriptive period under Article 1391. The decision demonstrates the courts' strict application of prescription rules and evidential requirements in contract annulment cases.

Statutes applied

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By the Intellegal Editorial Board · October 18, 2007

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