Case Summary (G.R. No. 129792)
Factual Background
Ariston Estrada filed a complaint on October 31, 1913, seeking a judicial declaration of his right to be subrogated in place of Reyes following a transaction involving the property in question. He alleged ownership of one-sixth of the land, which he claimed was a communal property among several coowners. This ownership was substantiated by Certificate of Title No. 2846 from the property registry in Manila. Estrada claimed the right to redeem the shares sold by Aragon and Del Rosario to Reyes by paying the purchase price of P399.99.
Procedural History
The defendant, Reyes, responded to Estrada's complaint with a general denial and a cross-complaint. She claimed to be the rightful owner of the shares based on a contract dated March 6, 1907, which involved former coowners and aimed to sell to Manuel Calvo y Perez. Following the death of Calvo, Reyes became the administratrix of his estate and sought the enforcement of the sale against the original sellers. In her defense, Reyes argued that she had a better title due to the court's prior judgment affirming the transfer of shares to her.
Legal Issues Presented
The primary legal questions revolved around the application of Article 1522 of the Civil Code, concerning the right of redemption among coowners of property. The court was tasked with determining whether Estrada or Reyes had a valid claim under this provision to redeem their respective shares against each other or to subrogate for the original sellers.
Court’s Analysis
The court analyzed the provisions of Article 1622 of the Civil Code to clarify the nature of the right of redemption. The law stipulates that coowners may exercise this right when another coowner sells their share to a third party. However, since both Estrada and Reyes acquired their shares from original owners and are therefore considered cotenants, neither party qualifies as a third party relative to the other. Consequently, the court concluded that both parties could not exercise their right of redemption against each other based on the definition established in the law.
Judgment
As neither Estrada nor Reyes held a better right to redemption against each other and given that both parties sought to claim ownership from original coowners, the court reversed the lower court's judgment. Both the complaint filed by Estrada and the cross-complaint by Reyes were dismissed without a special finding regarding costs
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Case Overview
- The case involves an appeal by Ariston Estrada against the judgment rendered on July 20, 1914, which absolved Cirila T. Reyes from Estrada's complaint and ordered Estrada to execute a document transferring his acquired share to Reyes for the amount of P166.66.
- The primary legal contention revolves around the right of redemption as stipulated in Article 1522 of the Civil Code, with both parties claiming entitlement to this right concerning their respective shares in a common property.
Factual Background
- Ariston Estrada asserted ownership of a sixth part of a property located in Calle Real, Malate, shared with other co-owners.
- The property ownership was documented under certificate of title No. 2846 in the Manila property registry.
- On October 29, 1913, Juan N. Aragon and Agustin del Rosario sold their interests in the property to Reyes for P266.66 and P133.33, respectively.
- Estrada attempted to exercise his right of redemption on October 30, 1913, offering to pay Reyes the amount she had paid for the shares, but Reyes refused his offer.
Legal Proceedings
- Reyes filed a cross-complaint, arguing that Estrada's purchase of his share from Luisa del Rosario was invalid d