Case Summary (G.R. No. L-1282)

Judicial Sale and Redemption Rights

• The Japanese occupation did not suspend the right to redeem properties when local courts were functioning regularly.
• The redemption period for properties sold at auction is not extended due to wartime conditions if the courts are operational.

Financial Hardship and Non-Redemption

• Financial hardship is not a valid excuse for failing to redeem properties after a judicial sale.
• A shortage of funds does not prevent the execution of a sale, emphasizing the importance of adhering to legal timelines.

Inadequacy of Price in Judicial Sales

• Mere inadequacy of the sale price is insufficient to annul a judicial sale.
• Courts will only intervene in cases where the inadequacy of price is so extreme that it shocks the conscience.
• The assessed value of the properties and the sale price must be considered, and in this case, the price did not shock the conscience.

Debt Moratorium and Redemption Money

• The debt moratorium under Executive Order No. 32 does not apply to redemption money, as it only prohibits the enforcement of debts through legal action.
• The judgment debtor is not considered in debt for the redemption money, and thus the moratorium does not affect the redemption period.
• Even if the moratorium were applicable, it would not revive a redemption period that had already expired.

Court's Deci...continue reading

Case Syllabus (G.R. No. L-1282)

Case Overview

• The case involves Juan S. Barrozo (plaintiff and appellant) seeking to repurchase his properties that were sold at a public auction after a court judgment against him.
• The sale occurred on April 28, 1941, and the plaintiff argues that the one-year redemption period should be extended due to the effects of World War II.
• The matter was submitted to the Court of First Instance of Pangasinan for resolution based on a stipulation of facts.

Background Facts

• Barrozo owned multiple parcels of land, which were subject to a mortgage with the Agricultural & Industrial Bank.
• A complaint by Tableria B and S against Barrozo led to a judgment ordering him to pay a debt, resulting in the execution and sale of his properties.
• These properties were sold to Jose B. Biagtan, who later transferred them to the defendant spouses Marcelino T. Macaraeg and Asuncion V. Sison-Macaraeg.

Legal Issues Presented

• The primary issue was whether the war conditions suspended or extended the statutory period for Barrozo to redeem his properties.
• Barrozo's position was that the Japanese occupation affected his ability to redeem the properties, and he sought relief from ...continue reading