Celsa Puncia Anchuelo v. Intermediate Appellate Court

Summary

The Anchuelo spouses owned seven parcels of land under free patent but faced financial difficulties requiring multiple mortgages. In 1961, they executed a deed of absolute sale to the Gavino spouses for P28,000.00 with a simultaneous agreement to resell after 19 years. The Anchuelos later claimed the transaction was fraudulent and sought to repurchase the land, arguing it was intended as a mortgage. The Supreme Court upheld lower court findings that the sale was valid and genuine. The Court ruled that the 19-year repurchase period violated Article 1601 of the Civil Code's 10-year maximum, giving petitioners until 1971 to redeem. Since no valid tender of payment was made within either the 10-year Civil Code period or the 5-year Public Land Law period, the repurchase right was lost. The case demonstrates the strict requirements for exercising redemption rights and the importance of proper tender of payment within prescribed periods.