Citation
G.R. No. 46640
Court
Supreme Court
Division
First Division
Decided
June 27, 1940

Summary

This 1940 Supreme Court case involved a land ownership dispute where Hugo Orilleneda challenged documents that allegedly transferred his property to Maria Aves and Segismundo Alzona. The Court of Appeals found that the purported sale documents were actually disguised mortgages used to conceal excessive interest on Orilleneda's P760 debt to Alzona. Despite the documents' language suggesting absolute sales, the court determined through parol evidence that the parties intended only to secure the debt, not transfer ownership. The Supreme Court affirmed this finding, emphasizing that contract interpretation may require extrinsic evidence to determine true intent. The case demonstrates judicial willingness to look beyond document language to prevent fraud and usury in private transactions involving real property.

Statutes applied

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By the Intellegal Editorial Board · June 27, 1940

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