Victorino del Castillo v. Pablo Escarella

Summary

This 1913 Supreme Court case involved a dispute over ownership of two hemp land parcels in Albay. Plaintiff Victorino del Castillo claimed he purchased the lands from defendant Pablo Escarella in 1901 for P1,200, paying P1,150 over several years with P50 remaining. After improving the lands for ten years, defendant usurped them in 1911, claiming plaintiff was merely a caretaker. The Court found the verbal sale contract valid under Civil Code articles 1278 and 1280, relying on documentary evidence (defendant's letters requesting payment) over oral testimony. The decision affirmed plaintiff's ownership rights, ordered return of the property, execution of proper deed, and payment of remaining balance. The case establishes important precedent on the validity of verbal real property contracts and the enforcement of incomplete sale agreements.