A.M. No. P-10-2788 - Office of the Court Administrator vs. Lopez

Petitioners Jose Fabia and Anita Fabia, originally defendants in a case filed by the respondents, petitioned for certiorari to review the decision of the respondent Intermediate Appellate Court dated October 21, 1983.
Respondents, represented by Carlina Rafanan, include Angel Mararac, Remedios Alejandro, Eugenio Mararac, Gildo Mararac, and Romeo Mararac.
The case originally arose from a dispute over the right of legal redemption under Article 1621 of the Civil Code, concerning a parcel of land allegedly subject to such right.

The land in question was previously owned by Hugo Mararac, who first sold it to Leonardo Mararac and Monica Resuello on March 27, 1971.
Leonardo Mararac and Monica Resuello subsequently sold the land to petitioners on February 25, 1975.
Prior to these transactions, adjoining lots were owned by other members of the Mararac family, establishing a complex chain of title and occupancy among related parties.

The land in question was described in various documents as “residential land” having a superficial area of approximately 1120 square meters.
It was bounded by identifiable landmarks and physical boundaries:

The property was fenced by earth dikes and bamboo fences, and elements such as a bamboo fence and fruit-bearing coconut trees were on the lot.
Despite the presence of some features (such as coconut trees, banana plants, and a fishwell) that could be associated with agricultural activity, the overall descriptive narrative and physical setting of the property clearly portrayed it as a residential area.

The land is located in Barrio Balogo, Binmaley, Pangasinan, an area generally characterized as a barrio rather than a city or town resembling a city.
The surrounding locality includes residential houses, a concrete house, semi-concrete and nipa houses, a chapel, an elementary school, and a public artesian well.
Although some agricultural improvements (e.g., coconut trees, banana plants) are present, the visual and functional characteristics of the neighborhood indicate a predominantly residential setting.

Documentary evidence, including exhibits and a tax declaration (Exhibit B), consistently described the property as residential.
The parties’ stipulation of facts and judicial admissions—such as the plaintiffs’ indication of residing on the adjoining lot—reinforced the residential characterization.
The trial court, after an ocular inspection on February 28, 1978, found that the evidentiary materials supported a residential rather than a rural description.

Petitioners requested that the respondents be allowed to redeem the property by depositing P8,000.00 and by executing a deed of sale to effectuate the redemption.
The trial court originally favored petitioners by denying the respondents’ claim for legal redemption, concluding that the evidence did not support a claim to rural land eligible for such redemption.

Whether the land in question may be considered rural, thereby qualifying for legal redemption under Article 1621 of the Civil Code.

Analysis centered on the land’s description, physical characteristics, and its functional use.
Key evidence included the tax declaration and description in the deed of sale, which labeled the property as “residential land.”

Whether respondents are barred by the doctrine of laches from redeeming the property even if it were considered rural.

The respondents argued that they had previously maintained the agricultural use of the property.
The issue further extended to whether any delay in asserting rights resulted in forfeiture through laches.