Case Digest (G.R. No. 113539)
Facts:
In this case, Celso R. Halili and Arthur R. Halili, owners of a lot adjoining a 6,695-square-meter parcel in Bagbaguin, Sta. Maria, Bulacan, filed suit against the Court of Appeals, Helen Meyers Guzman, David Rey Guzman, and Emiliano Cataniag. The property formed part of the inheritance of Simeon de Guzman, an American citizen who died in 1968, leaving his widow Helen and son David Rey, both American citizens, as forced heirs. On August 9, 1989, Helen quitclaimed her interest to David Rey, resulting in the cancellation of Transfer Certificate of Title No. T-170514 and the issuance of T-120259 in David Rey’s name. On February 5, 1991, David Rey sold the land to Emiliano Cataniag, who obtained TCT No. T-130721(M). The Halilis invoked Article 1621 of the Civil Code to assert a right of redemption and challenged the constitutionality of both conveyances under the 1987 Constitution, contending that the transfer to an alien was void. On March 10, 1992, the Regional Trial Court of MaloCase Digest (G.R. No. 113539)
Facts:
- Parties and Inheritance
- Simeon de Guzman, an American citizen, died in 1968, leaving several real properties in the Philippines.
- His forced heirs were his widow, Helen Meyers Guzman, and his son, David Rey Guzman—both American citizens.
- Conveyances and Title Transfers
- On August 9, 1989, Helen executed a quitclaim deed in favor of David Rey covering six inherited parcels, including a 6,695 sqm lot in Bagbaguin, Sta. Maria, Bulacan (TCT No. T-170514), which was reissued as TCT No. T-120259 in David Rey’s name.
- On February 5, 1991, David Rey sold the same lot to Emiliano Cataniag; TCT No. T-120259 was cancelled and reissued as TCT No. T-130721 in Cataniag’s name.
- Procedural History
- Petitioners Celso R. Halili and Arthur R. Halili, owners of an adjoining lot, sued in the RTC of Malolos, Bulacan, contesting both conveyances on constitutional grounds and claiming redemption under Art. 1621 of the Civil Code.
- On March 10, 1992, the RTC dismissed the complaint: (a) Helen’s waiver was not unconstitutional; (b) the lot was urban, precluding Art. 1621 redemption.
- The Court of Appeals (Sep. 14, 1993) affirmed the RTC decision, also ruling that the subsequent sale to Cataniag (a qualified Filipino) cured any defect in the prior transfer.
- Petitioners filed a Rule 45 petition in the Supreme Court to set aside the CA decision.
Issues:
- Whether the subject land is urban rather than rural.
- Whether petitioners may invoke their right of redemption under Art. 1621 of the Civil Code.
- Whether the quitclaim deed from Helen to David Rey, deemed unconstitutional, should have been declared null and void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)