Case Summary (G.R. No. L-21677)
Factual Background
The case arises from a contract of exchange executed on October 1, 1958, between the City of Manila and Arellano University, Inc., based on Resolution No. 442 of the Municipal Board of Manila. This contract involved the exchange of five parcels of land owned by the City of Manila for three parcels belonging to Arellano University, needed for the extension of Azcarraga Street.
Contentions of the Parties
Antonio G. de Santos initiated a legal action to declare the contract of exchange void concerning Lot No. 1 of Psu-167195, asserting his rights of redemption and pre-emption. The defendants, City of Manila and Arellano University, denied any preferential rights claimed by the petitioner. Arellano University counterclaimed for attorney's fees due to the allegedly unfounded complaint.
Trial Court Ruling
The trial court sided with the respondents, holding that Santos had no rights of pre-emption or redemption regarding Lot No. 1, ruling that he was not an interested party to challenge the validity of the contract. Consequently, the complaint was dismissed, and Santos was ordered to pay Arellano University attorney's fees.
Appellate Court's Affirmance
The Court of Appeals affirmed the trial court's decision, emphasizing that the assertions made by Santos regarding his preferential rights were unsubstantiated by evidence or law, particularly under Article 1622 of the new Civil Code, which delineates the conditions necessary for establishing such rights.
Analysis of Pre-emption and Redemption Rights
Article 1622 provides conditions for the right of pre-emption to an adjoining landowner. The Court determined that Santos failed to demonstrate that Lot No. 1 was so small and located in a manner that it could not be used practically, nor did he show that it had been acquired solely for speculative purposes. The findings were further supported by the fact that the lot in question was larger than the average residential lot and adjacent to Arellano University, which had legitimate educational needs for the property.
Findings on Contract Validity
The Court maintained that Santos could not claim nullification of the deed of exchange since he was neither a principal nor an interested party under the contract. His alleged detriment from the agreement was found inadequate to establish a legal bas
...continue readingCase Syllabus (G.R. No. L-21677)
Case Background
- Petitioner-appellant: Antonio G. De Santos
- Respondents-appellees: City of Manila and Arellano University, Inc.
- Case Reference: 150-A Phil. 798 [G.R. No. L-21677. June 29, 1972]
- Initial decision by the Court of Appeals dated July 11, 1963, affirmed the ruling of the Court of First Instance of Manila in Civil Case No. 39730.
Factual Summary
- On October 1, 1958, a contract of exchange was executed between the City of Manila and Arellano University, Inc., governed by Resolution No. 442, which was adopted on August 15, 1958.
- The exchange involved five parcels of land owned by the City of Manila, totaling 2,458.3 square meters, for three parcels of land from Arellano University, totaling 2,171.4 square meters, needed for the construction of the Azcarraga Extension.
- Antonio G. De Santos filed an action on March 25, 1959, against the City of Manila and Arellano University, seeking to:
- Declare the contract null and void concerning Lot No. 1 of Psu-167195.
- If the contract was upheld, declare Lot 1 subject to his right of redemption within 30 days from written notice.
- Enjoin the City from acquiring the property if it was determined not to belong to them, ensuring respect for his right of preemption.
Legal Proceedings
- Arellano University filed an answer with a coun