- Petitioner
- Sps. Ester Santiago
- Respondent
- Aida G. Dizon
- Citation
- G.R. No. 172771
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Carpio-Morales, J.
- Decided
- January 31, 2008
Summary
Aida Dizon sought reformation of a deed of sale, claiming her P550,000 sale of property to the Santiago spouses was actually an equitable mortgage. After Monte de Piedad foreclosed her mortgaged property, Elizabeth Santiago paid P550,000 to buy it back for Dizon, who immediately sold it to petitioners for the same amount with a 3-month repurchase option at P900,000. The RTC and Court of Appeals found the transaction was an equitable mortgage based on price inadequacy and Dizon's continued possession. However, the Supreme Court reversed, holding that the presumption of equitable mortgage was rebutted by evidence showing petitioners exercised ownership rights, paid taxes, collected rentals, and that the purchase price was adequate compared to the property's assessed value of P29,850. The case established that continued possession alone does not conclusively prove equitable mortgage when other evidence demonstrates genuine sale.