Case Summary (G.R. No. 194388)
Legal Proceedings
In civil case No. 9031 filed by Dolores Vasquez in the Court of First Instance of Iloilo, a judgment was issued against her husband, Mariano B. Arroyo, for alimony payments of P500 per month starting in February 1932. When Arroyo failed to comply, Vasquez obtained an execution order leading to the public auction sale of a parcel of land. This sale occurred on July 27, 1935, whereby Vasquez purchased the property for P4,500. The subsequent final certificate of sale was executed on August 10, 1936.
Third-Party Claim and Property Dispute
Carlos Doronila intervened by filing a third-party claim with the Provincial Sheriff of Iloilo opposing the sale, asserting that the property had been conveyed to him through two different agreements with Arroyo, namely a sale by installment in June 1933 and a definite sale in February 1935. In a subsequent civil case (No. 10269), the court ruled that Doronila's claims were void due to their fraudulent nature intended to defraud creditors, thus confirming the validity of the sale to Vasquez.
Redemption Attempts
On April 12, 1937, Doronila attempted to redeem the property by depositing the amount of P4,608, which included the auction price and interest. However, his request was refused by the provincial sheriff on the grounds that the statutory redemption period had expired. Doronila subsequently instituted civil case No. 10874 to annul the sheriff's deed in favor of Vasquez and compel the redemption of the property.
Trial Court's Dismissal
The trial court dismissed Doronila's complaint, primarily concluding that the statutory period for redeeming the property—twelve months post-sale—had elapsed. While six errors were cited in Doronila's appeal, the core matters revolved around the right to redeem and the expiration of the redemption period.
Statutory Provisions and Judicial Interpretation
According to Section 465 of the Code of Civil Procedure, redemption can be exercised within twelve months following a sale. The court acknowledged that Doronila's redemption request exceeded this statutory timeframe, barring any legal exceptions. Although Doronila argued for equitable relief to allow redemption despite the elapsed time, the court found his claims lacking merit due to the fraudulent nature of his prior dealings with Arroyo that were aimed at evading creditor claims.
Fraud and Creditor Rights
The ruling emphasized that Doronila was complicit in Arroyo's schemes to defraud creditors, especially given that the sale he relie
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Case Overview
- The case involves a dispute over the ownership of a parcel of land following a public auction conducted due to a judgment for alimony.
- Plaintiff Carlos Doronila appeals against the decision of the trial court which upheld the validity of the auction sale and dismissed his claims of ownership.
- The case highlights issues of fraudulent conveyance, redemption rights, and equitable considerations in the context of civil procedure.
Background of the Case
- Dolores Vasquez de Arroyo secured a judgment for alimony against her husband, Mariano B. Arroyo, in February 1932.
- Due to Mariano's non-compliance, Dolores obtained an order of execution leading to the sale of a parcel of land on July 27, 1935, which was auctioned to her for P4,500.
- Carlos Doronila filed a third-party claim against this sale but was unsuccessful as the provincial sheriff completed the sale.
Legal Proceedings and Claims
- Doronila initiated Civil Case No. 10269, seeking to annul the auction sale and asserting ownership based on two transactions with Mariano: a sale by installment in June 1933 and a definitive sale in February 1935.
- The trial court ruled that Doronila's claim was fraudulent and upheld the sale to Dolores Vasquez.
- The Court of Appeals affirmed thi