Facts:

The case involves Santiago Ortega as the plaintiff-appellant and Andres Orcine and Doroteo Esplana as the defendants-appellees. The events transpired in Iriga, Camarines Sur, with the decision being rendered on March 31, 1971. Santiago Ortega owned a parcel of land that was utilized as a school site for the Saint Anthony Academy. He sought to enforce his alleged right of legal redemption under Article 1622 of the Civil Code over an adjoining 4,452-square-meter parcel of land that had been sold by Orcine to Esplana. Initially, Ortega's complaint was based on Article 1621 of the New Civil Code, but after a motion to dismiss was filed by the defendants, the court ordered Ortega to clarify whether his land was rural. Following this, Ortega amended his complaint to invoke Article 1622 instead. The defendants filed another motion to dismiss, which was denied. The case was eventually set for oral arguments, and it was established that the land sold to Esplana was originally agri...

Facts:

1. Parties Involved:

   • Plaintiff-Appellant: Santiago Ortega, owner of a parcel of land in Iriga, Camarines Sur, used as a school site by Saint Anthony Academy.
   • Defendants-Appellees: Andres Orcine and Doroteo Esplana, who sold and purchased an adjoining 4,452-square-meter parcel of land.

2. Nature of the Land:

   • The land sold by Orcine to Esplana was originally a ricefield (agricultural/rural land).
   • After the sale, Esplana filled the land with earth and subdivided it into small lots for residential purposes, converting it into urban land.
   • Ortega’s land, adjacent to the sold land, was already urban at the time of the sale and was being used as a school site.

3. Legal Basis for the Case:

   • Ortega filed a complaint to enforce his right of legal redemption under Article 1622 of the Civil Code over the adjoining land sold by Orcine to Esplana.
   • Initially, Ortega based his claim on Article 1621 (right of legal redemption for rural lands), but later amended his complaint to rely on Article 1622 (right of pre-emption or redemption for urban lands).

4. Procedural History:

   • The trial court dismissed the case, ruling that Ortega’s land was urban while the sold land was rural at the time of the sale, making Article 1622 inapplicable.
   • Ortega appealed, arguing that the nature of the land at the time of redemption (urban) should govern, not its nature at the time of sale.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Purpose of Legal Redemption:

   • Article 1621 (rural lands): The purpose is to encourage the consolidation of small agricultural lands for better development and utilization.
   • Article 1622 (urban lands): The purpose is to discourage speculation in real estate and address housing problems in populated areas.

2. Conditions for Legal Redemption under Article 1622:

   • The land must be "so small and so situated that a major portion thereof cannot be used for any practical purpose within a reasonable time."
   • The land must have been "bought merely for speculation."
   • These conditions were not met in this case, as the land was developed into a subdivision and was not purchased for speculative purposes.

3. Nature of the Land:

   • The classification of land as rural or urban depends on its location and use, not just its physical characteristics.
   • Even if a land is used for agriculture, it can still be considered urban if it is located in a populated area.

4. Speculation:

   • Speculation involves purchasing property with the expectation of profiting from price fluctuations, often without a clear business purpose.
   • Esplana’s actions (developing the land into a subdivision) showed a clear business purpose, not mere speculation.

Conclusion:

The Supreme Court ruled that Ortega was not entitled to the right of legal redemption under Article 1622 because the land in question did not meet the required conditions (size, usability, and speculative purpose). Additionally, Article 1621 did not apply because Ortega’s land was urban, while the sold land was rural at the time of the sale. The decision of the lower court was affirmed, and Ortega’s appeal was dismissed.