G.R. No. 219556 - Rama vs. Spouses Nogra

The case involves an undivided portion (one-fourth share) of Lot No. 6034-C-2-H-4, with an area of 129 square meters, located along V. Rama St., Barangay Guadalupe, Cebu City.
The lot is registered in the name of the heirs of Felix Rama, including petitioners Hermelina Rama and her daughter Baby Rama Lauron, and respondents Ricardo Rama, Lucina Rama Yamyamin, and Victoria Rama Fajardo.

On September 10, 1992, respondent Ricardo Rama sold his one-fourth undivided share to respondents Spouses Medardo and Purita Nogra for P35,000.00 payable in installments.
Upon full payment, a Deed of Absolute Sale was executed on July 13, 2001.

Petitioners claimed that they had no knowledge of the sale until conciliation proceedings were conducted before the barangay on July 25 and September 9, 2007.
Ricardo and Spouses Nogra confirmed the sale during these proceedings.
Hermelina offered to redeem the property but respondents refused to provide a copy of the Deed of Absolute Sale and details of the sale.

After respondents surveyed the property for partition (shortly after the barangay proceedings), petitioners confronted Ricardo on September 26, 2007, and were given a copy of the Deed of Absolute Sale.
Petitioners then filed a Complaint for Annulment of Sale, Redemption, and Other Reliefs before the Regional Trial Court (RTC) on October 16, 2007.
They consigned the full redemption price on October 26, 2007.

Spouses Nogra claimed that Ricardo gave Hermelina a written notice of sale on August 31, 1992, evidenced by a postal registry return slip (without the actual letter).
Respondents also argued Hermelina had actual knowledge of all conveyances due to her participation in ejectment proceedings against Lucina Rama regarding her share.

RTC ruled that the 30-day redemption period under Article 1623 NC only began on September 26, 2007, when petitioners received the written notice (copy of the deed) from Ricardo. RTC held that the postal registry slip alone was insufficient proof of written notice in 1992. (Decision dated October 25, 2011)
Spouses Nogra appealed to the Court of Appeals (CA).
CA set aside the RTC decision, ruling that written notice could be dispensed with because petitioners had actual knowledge of the sale: through Ricardo’s admission during the 2007 barangay conciliation and Hermelina’s involvement in Lucina’s ejectment case gave constructive notice. Thus, the 30-day period ran from 1992 to 2007, and petitioners were out of time to redeem. (CA Decision dated January 26, 2015)
CA denied petitioners’ motion for reconsideration on June 10, 2015.
Hermelina died and was succeeded by Baby Rama Lauron, who filed this petition for review on certiorari.

Whether the filing of the Complaint for Annulment of Sale, Redemption, and Other Reliefs on October 16, 2007, by Hermelina (and subsequently Baby) validly exercised the right of redemption under Article 1623 of the New Civil Code.

Whether the written notice requirement under Article 1623 may be dispensed with due to the co-owners' alleged actual knowledge of the sale.