G.R. No. 10329 - Estrada vs. Reyes

The plaintiff and appellant, Ariston Estrada, and the defendant and appellee, Cirila T. Reyes, are involved in a dispute over interests in a parcel of land.
The property in question is situated in Malate, Manila, specifically in Calle Real, interior, with its boundaries and extent delineated by a plan and evidenced by Certification of Title No. 2846.
The land is owned in common by several individuals including Estrada along with Juan N. Aragon, Agustin del Rosario, Jose Pereyra, Remedios Pereyra, Ramon Pereyra, Inocencio Pereyra, and Carmen Pereyra.

On October 31, 1913, Estrada filed a complaint seeking to be subrogated in place of Reyes in connection with a sale executed by Juan N. Aragon and Agustin del Rosario.

He claimed a right to redeem, under Article 1522 of the Civil Code, the sale interests after paying an amount of P399.99.
Estrada alleged that being one of the cotenants, he was entitled to the right of redemption by repurchasing the interest acquired by the defendant.

On October 29, 1913, Juan N. Aragon and Agustin del Rosario sold and transferred their respective shares in the disputed property to Cirila T. Reyes.

On March 20, 1912, prior to the transfers to Reyes, Estrada acquired a one-sixth interest in the property from Luisa del Rosario for P166.66.
On October 30, 1913, when Estrada was notified of the transfer to Reyes, Reyes herself attempted to exercise her right of redemption by offering to repurchase the interest from Estrada by paying the same sum (P166.66).

Estrada refused the offer, leading Reyes to seek an order directing him to execute the corresponding deed of transfer.

In her amended answer, Reyes not only denied key allegations but also asserted a special defense by way of a cross-complaint.

The cross-complaint emphasized the existence of a prior contract executed on March 6, 1907, by various parties favorable to Manuel Calvo y Perez for the sale of the property once a Torrens title was secured.
Relevant exhibits (Exhibit A: the said contract; Exhibit B: a letter by the administratrix; Exhibit C: the October 23, 1911, decision) were introduced to establish a chain of title and contractual obligations.

Certain parties involved in the earlier contract were either not cotenants or did not have an actual share in the property.
A judgment was rendered ordering Juan N. Aragon and Agustin del Rosario to transfer their shares to Reyes, which Estrada’s subsequent actions did not negate.

The dispute, therefore, centers on the conflicting claims of redemption where both Estrada and Reyes invoke their rights as cotenants under the Civil Code.

The lower court, in its judgment dated July 20, 1914, absolved Reyes of the initial complaint and ordered Estrada to execute a deed transferring his acquired share to Reyes.
Estrada appealed the said judgment through a bill of exceptions, which was subsequently brought to the appellate court.

Whether Ariston Estrada and Cirila T. Reyes are considered co-owners (cotenants) with equal rights, or whether one of them may be categorized as a third party in relation to the other.
The determination hinges on the method of acquiring their respective shares from the original owners.

Whether either party is entitled to exercise the right of redemption on the portion of the property they acquired.
Whether the right of redemption can be exercised by one cotenant against another, or if it is exclusively applicable when redeeming an interest sold to a third party.
The interpretation and application of Article 1522 (as invoked by the parties) alongside the relevant provisions (specifically the provision which states: “A coowner of a thing held in common may exercise the redemption in case the shares of all the other coowners, or of any of them, are sold to a third party”).

Whether the earlier acquisition by Estrada prior to the sale to Reyes gives him a superior right of redemption.
The importance of the dates of the transactions and the corresponding orders of transfer as established by the earlier judgments and agreements.