Aniceta Ramirez v. The Court of Appeals

Summary

This case involved competing claims over the same parcel of land based on two deeds of sale. The Ramirez family claimed their 1965 sale to Maria vda. de Ramos was invalid due to non-payment, while the Ramos spouses asserted that Benedicto's 1977 conveyance to Vicente Aniñon was merely an equitable mortgage. The Supreme Court affirmed the Court of Appeals' finding that the first sale was validly consummated with full payment, rejecting claims of non-payment as unsupported by evidence and noting the absence of any rescission action. The Court applied Article 1602 of the Civil Code to determine that the second deed constituted an equitable mortgage rather than an absolute sale, based on the vendor's continued possession of the property and evidence that the transaction was intended to secure debt payment rather than transfer ownership. The decision established that contemporaneous and subsequent conduct of parties is determinative of a transaction's true nature.