Case Summary (G.R. No. L-8029)
Procedural History
This case is a Petition for Review on Certiorari challenging the July 7, 2000 decision of the Court of Appeals (CA) in CA-GR CV No. 55264, which reversed the decision of the Regional Trial Court (RTC) of Dagupan City. The RTC had ruled in favor of the petitioners, granting them the right to redeem the property previously sold to the respondents. However, the CA held that the petitioners were not entitled to redemption for several reasons, leading to this appeal.
Factual Background
The original co-ownership of Lot No. 2991 included several individuals, notably Angel Fernandez and his siblings. The property was sold in segments to the Tarun spouses by Angel’s co-owners, Antonio and Demetria Fernandez, in 1967. A Deed of Extrajudicial Partition executed later recognized these sales. Despite the sale, Angel Fernandez and later his heirs continued to possess the entirety of the property, prompting the Taruns to seek partition.
Ruling of the RTC
The Regional Trial Court ruled in favor of the petitioners, asserting that they were entitled to the right of redemption under Articles 1620 and 1621 of the Civil Code. The RTC suggested that the sale was iniquitous due to the absence of required notice under Article 1623.
Ruling of the Court of Appeals
In contrast, the Court of Appeals reversed this ruling. It found that Angel Fernandez, the predecessor of the petitioners, had not exercised the right to redeem when the sale occurred. The CA held that the Deed of Extrajudicial Partition provided sufficient notice, thus triggering the expiration of the petitioners’ redemption rights. The CA also emphasized that the sale did not constitute an equitable mortgage as arguable by the petitioners.
Legal Issues Presented
The petitioners raised multiple issues including:
- Their entitlement to exercise the right of legal redemption.
- Whether the transaction constituted an equitable mortgage.
- The validity of the Deed of Extrajudicial Partition.
- Their entitlement to damages and attorney's fees.
- Allegations of factual inconsistencies and errors by the CA.
Resolution of Legal Issues
First Issue: Entitlement to Legal Redemption
The Supreme Court concluded that the right of redemption, as outlined in Article 1620, applies only when the shares of co-owners are sold to a third party. Since the spouses Tarun had become co-owners through prior transactions, petitioners could not claim the right of redemption.
Second Issue: Equitable Mortgage
The Court dismissed the petitioners' argument that the transaction was an equitable mortgage, emphasizing the requirement of a contract where both parties intended a mortgage. The price paid was not deemed inadequate without evidence of the property's fair market value.
Third Issue: Validity of the Extrajudicial Partition
The Court affirmed that the extrajudicial partition was valid and binding. It ruled that the petitioners, as successors-in-interest, are bound by the agreements of their predecessor, Angel Fernandez, and the consent given was valid as stipu
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Case Overview
- This case involves a Petition for Review on Certiorari challenging the Decision of the Court of Appeals, which reversed the Regional Trial Court's ruling regarding the partition of a fishpond property co-owned by the petitioners and respondents.
- The primary legal issue revolves around the right of redemption, co-ownership, and the validity of a sale between co-owners.
Background of the Case
- The property in question is an 8,209-square meter fishpond in Dagupan City, known as Lot No. 2991, co-owned by the Fernandez family and the Taruns.
- The original co-owners included brothers Antonio, Santiago, Demetria, and Angel Fernandez, along with their uncle Armando.
- The ownership structure changed over time, especially after the death of Armando, leading to a reallocation of shares among the remaining co-owners.
- Antonio and Demetria Fernandez sold portions of the lot to the respondents, Spouses Tarun, leading to disputes regarding the partition and rights to the property.
Ruling of the Regional Trial Court (RTC)
- The RTC ruled in favor of the petitioners, granting them the right to redeem the property based on Articles 1620 and 1621 of the Civil Code, declaring the sale iniquitous and void due to non-compliance with legal notice requirements.
Ruling of the Court of Appeals (CA)
- The CA reversed the RTC's decision, stating that:
- The right of redemption was not available as the property was sold to co-owners (the respondents).
- The execution of the Deed of Extraju