Heirs of Remulador Cuyos v. Heirs of Teresita Carrasco

Summary

The Supreme Court affirmed lower courts' ruling that a 1986 Deed of Absolute Sale between Teresita Carrasco and Remulador Cuyos over an 18,698 square meter land was actually an equitable mortgage. Teresita had borrowed P15,000.00 but the deed showed only P5,000.00 as consideration, which was grossly inadequate. The failure of Remulador and his heirs to transfer the title for over 30 years further supported the equitable mortgage presumption under Articles 1602 and 1604 of the Civil Code. The Court ordered the heirs to return the title and possession upon payment of the P15,000.00 debt, rejecting arguments about land reversion and procedural defects. This case demonstrates the protective nature of equitable mortgage doctrines against unfair property transactions.