Felix Angao v. Nicolas Clavano

Summary

This case involved a dispute over the right to repurchase land sold under pacto de retro. Felix Angao sold coconut land to Ambrosio Bugahud in 1899 with a condition that he could redeem it within one year after his marriage. Bugahud transferred his rights to Nicolas Clavano. Angao married in September 1903 but failed to redeem the property within the stipulated one-year period, attempting redemption only in August 1906. The Supreme Court affirmed the lower court's decision, holding that Angao's redemption right had lapsed by operation of law when he failed to exercise it within the contractual period. The Court emphasized that under Civil Code Articles 1508, 1509, and 1518, a vendor must actually tender payment within the redemption period, not merely express intent to redeem. This case establishes important precedent on the strict enforcement of redemption periods in pacto de retro sales and the requirements for valid redemption under Philippine civil law.