Facts:

• Two parcels of land were originally co-owned by Alfredo Benito, Mario Benito, and Benjamin Benito, covered by Transfer Certificates of Title Nos. T-609 and T-610 in Sorsogon.
• Mario Benito died in January 1957, and his estate was jointly administered by his widow, Basilia Lahorra Vda. de Benito, and his father, Saturnino Benito.
• On August 26, 1959, Benjamin Benito sold his one-third undivided share of the land to Luz Caro for P10,000. This sale was registered on September 29, 1959.
• With the consent of Alfredo and Saturnino Benito, the land was subdivided, and a subdivision title was issued to Luz Caro in 1960.
• Basilia Lahorra learned of the sale in May 1966 and sought to redeem the property in August 1966, but her offer was ignored.
• Basilia Lahorra filed a complaint in the trial court, claiming she had not been notified of the sale as required by law.
• The trial court dismissed the complaint, but the Court of Appeals reversed this decision, ordering Caro to execute a deed of redemption.
• Luz Caro then petitioned the Supreme Court for review.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the right of legal redemption does not exist in this case because the co-ownership was terminated through subdivision and distribution of the property.
2. The Court held that the private respondent, as administratrix, did not have the personality to exercise the right of legal redemption.
3. The Court found that there was no ne...(Unlock)

Ratio:

• The Supreme Court's decision was based on several legal principles and precedents.
• The purpose of the right of legal redemption is to reduce the number of co-owners until the co-ownership is terminated.
• Since the property had already been subdivided and distributed among the co-owners, the co-ownership had effectively ended, and thus, the right of legal redemption no longer applied.
• This was supported by the case of Caram vs. Court of Appeals, which held that once property is subdivided and distributed, the community is terminated, and there is no reason to sustain any right of legal redemption...continue reading