Ramon Mortera v. Inocente Martinez

Summary

This Supreme Court case established the continued validity of pacto de retro (sale with right of redemption) contracts under Philippine law. Ramon Mortera sought land registration of property acquired through a chain of title involving a pacto de retro sale. Inocente Martinez originally sold the land to Jose de Guzman with a 40-day redemption right, executed through his attorney-in-fact. When the redemption period expired, Guzman's ownership was confirmed and he subsequently sold to Mortera. Martinez and Exequiela Buñi opposed registration, claiming the attorney exceeded his authority and asserting competing claims. The Supreme Court affirmed Mortera's right to registration, holding that Act No. 1108 did not repeal Civil Code provisions on pacto de retro but merely provided for their registration. The decision clarified that pacto de retro contracts remain valid and enforceable, with registration protecting legitimate transfers against unregistered competing claims.