Leona Ramos v. Francisco Icasiano

Summary

This case involved a dispute over the right to repurchase land under a pacto de retro arrangement. Vicenta Fajardo sold land to Francisco Icasiano in 1903 with a 14-year repurchase right. After Fajardo's death, his heirs and Icasiano executed an agreement in 1905 modifying the redemption terms to be exercised after fourteen years. The heirs later sought to compel the current landowners to sell the property to them. The Supreme Court ruled against the heirs, holding that the 1905 agreement violated Civil Code Article 1508's ten-year maximum limitation for redemption periods. The Court distinguished between sales with pacto de retro and promises to sell, finding this case fell under the former category. The decision established that agreements suppressing redemption rights during the entire lawful period are invalid, and statutory time limits cannot be circumvented by subsequent agreements.