Macario Facundo v. Hermenegilda Macapagal

Summary

This 1915 Supreme Court case involved a land ownership dispute where plaintiff Macario Facundo claimed he had mortgaged land to Pio de Guzman in 1890 for P23 and sought to redeem it from the latter's successor. However, the Supreme Court found that plaintiff's own 1895 possessory information application clearly described the transaction as a sale with right of repurchase, not a mortgage. Applying Civil Code art. 1508, the Court ruled that without an express redemption period, plaintiff had only four years (1890-1894) to exercise his right of repurchase. Since he failed to do so, his right prescribed, and absolute ownership consolidated in the vendee's successor, who validly sold the land to defendant Crisostomo in 1903. The Court reversed the lower court's judgment and absolved Crisostomo, emphasizing the importance of documentary evidence and the legal consequences of failing to exercise redemption rights within the prescribed period.