Case Summary (G.R. No. 66101)
Applicable Law
The case deals primarily with Article 1621 of the Civil Code of the Philippines, which provides owners of adjoining lands the right of redemption when a piece of rural land, not exceeding one hectare, is alienated unless excluded by the presence of certain separating features such as brooks, drains, or roads.
Background and Facts
The land in question originally belonged to Hugo Mararac, who sold it to spouses Leonardo Mararac and Monica Resuello in 1971. Subsequently, the latter sold the property to the petitioners in 1975. The respondents, living adjacent to this land, filed a complaint to exercise their right of legal redemption. During the pre-trial conference, a stipulation of facts was established detailing the neighbors' residences and the land's characteristics.
Initial Decision of the Trial Court
The trial court held in favor of the petitioners, finding that the respondents failed to prove that the land was rural and therefore deserving of legal redemption. It highlighted discrepancies in the characterization of the land as "residential," based on both the complaint and the evidence presented, which contradicted the requirement under Article 1621 for the land to be categorized as rural.
Ruling by the Intermediate Appellate Court
Upon appeal, the Intermediate Appellate Court reversed the trial court's decision, asserting that the property in question was rural due to its location in a barrio and the presence of agricultural improvements. It emphasized that the classification hinged on the land's characteristics and its use, permitting the respondents to redeem the land within a specified timeframe.
Petition for Certiorari
A petition for certiorari was subsequently filed to assess whether the land could be considered rural for legal redemption purposes and to address issues of laches allegedly affecting the respondents' rights. The petitioners argued against the appellate court's characterization of the land, claiming it was primarily residential.
Legal Definitions and Characterization
The petitioners cited definitions from legal literature to emphasize the difference between urban and rural lands, arguing that the use of the land for residential purposes disqualified it from being treated as rural under Article 1621. They underscored that admissions made in the complaint bind the respondents and refute their claims to redemption.
Conclusion on Property Classification
The court's analysis led to the conclusion that the respondents did
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Case Citation
- G.R. No. L-66101
- Date of Decision: November 21, 1984
- Division: First Division
- Justices Involved: Gutierrez, Jr., Melencio-Herrera, Plana, Relova, De La Fuente, Teehankee
Background of the Case
- The case involves a petition for certiorari to review a decision by the Intermediate Appellate Court dated October 21, 1983.
- Petitioners, Jose and Anita Fabia, were previously defendants in a legal action initiated by the respondents, Angel Mararac and others, to exercise their right of legal redemption over a parcel of land sold to the petitioners.
- The right of legal redemption is provided under Article 1621 of the Civil Code of the Philippines, which pertains to adjacent landowners' rights when a piece of rural land is alienated.
Summary of Facts
Parties Involved:
- Petitioners: Jose and Anita Fabia
- Respondents: Angel Mararac and others, represented by their mother, Carlina Rafanan.
Key Events:
- The land in question was originally owned by Hugo Mararac and sold to Leonardo Mararac and Monica Resuello in 1971.
- Petitioners purchased the land from Leonardo and Monica on February 25, 1975.
- The respondents, who reside on adjacent property, filed the complaint for legal redemption without prior offers during the sales.
Land Characteristics:
- The land has been described as residential in various documents.
- It is bounded by a barrio road and not separated by any natural barriers.
- The land was fenced and had various plantings, including coconut and banana trees.
Procedural History
- The trial court ruled in favor of the