Case Digest (G.R. No. 45748) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Angela M. Butte v. Manuel Uy & Sons, Inc., the decedent, Jose V. Ramirez, held an undivided one-sixth (1/6) interest in a house and lot in Sta. Cruz, Manila (TCT No. 52789), co-owned equally with five others including Marie Gamier Vda. de Ramirez. Jose V. Ramirez died on October 20, 1951; his will bequeathed one-third (1/3) of his free estate to Mrs. Angela M. Butte, and probate was opened (Special Proceeding No. 15026) with the Bank of the Philippine Islands appointed judicial administrator. The estate remained unsettled due to creditor claims. On December 9, 1958, Marie Gamier, by her attorney-in-fact, sold her 1/6 share to Manuel Uy & Sons, Inc. for ₱500,000, filed the required affidavit that written notices had been sent to all possible redemptioners, and registered the sale. The purchaser’s and vendor’s notices were delivered to the judicial administrator and forwarded to Mrs. Butte’s counsel, reaching Mrs. Butte between December 11 and 19, 1958. On January 15, 1959, Mrs Case Digest (G.R. No. 45748) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Co-ownership and succession
- Transfer Certificate of Title No. 52789 for a house and lot in Sta. Cruz, Manila, listed six undivided co-owners, each holding a 1/6 share, including Jose V. Ramirez.
- On October 20, 1951, Jose V. Ramirez died. Special Proceeding No. 15026 was instituted for settlement of his estate. His will, bequeathing one-third of the free portion to Angela M. Butte, was admitted to probate, but final distribution remained pending due to creditors’ claims exceeding the estate’s assets. The Bank of the Philippine Islands was appointed judicial administrator.
- Sale of 1/6 share and notices
- On December 9, 1958, Marie Gamier Vda. de Ramirez, co-owner of a 1/6 share, sold it to Manuel Uy & Sons, Inc. for ₱500,000. An affidavit by her attorney-in-fact confirmed that notices had been sent to all possible redemptioners. The deed was registered, and a new title was issued.
- On the same day, Uy & Sons notified the judicial administrator. On December 11, 1958, the vendor’s attorney-in-fact also sent notice to the administrator. Through a chain of endorsements, Mrs. Butte received the buyer’s letter on December 11 or 12 and the vendor’s notice on December 19, 1958.
- Tender, refusal, trial and appeal
- On January 15, 1959, Mrs. Butte, through counsel, sent a letter and a PNB cashier’s check for ₱500,000 to Uy & Sons, offering to redeem the 1/6 share. The offer was refused. She then consigned the amount in court and filed for legal redemption, praying for conveyance of the share and for damages.
- The Court of First Instance of Manila dismissed the complaint, ruling that Mrs. Butte had no right to redeem and that, if she did, her tender was beyond the 30-day period under Articles 1620 and 1623 of the Civil Code. Both parties appealed to the Supreme Court.
Issues:
- May plaintiff-appellant, as a testamentary heir with a contingent interest in Jose V. Ramirez’s 1/6 share, exercise the right of legal redemption against a third-party purchaser despite pending estate proceedings and a judicial administrator?
- Did plaintiff-appellant tender the redemption price within the 30-day period prescribed by law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)