Case Summary (G.R. No. 113539)
Petitioners
The Halilis sued to annul two conveyances affecting the disputed parcel and to exercise the right of redemption under Article 1621 of the Civil Code as adjoining landowners.
Respondents
Helen Meyers Guzman executed a quitclaim assigning her inheritance share to her son, David Rey Guzman. David Rey subsequently sold the parcel to Emiliano Cataniag, who holds the title reflected in TCT No. T-130721(M).
Key Dates
Quitclaim from Helen to David Rey: August 9, 1989. Sale from David Rey to Cataniag: February 5, 1991. Trial court decision dismissing complaint: March 10, 1992. Court of Appeals decision affirming dismissal: September 14, 1993. Supreme Court decision denying the petition: March 12, 1998.
Applicable Law
Constitutional provision applied: 1987 Constitution, Article XII, Section 7 (prohibiting transfer of private lands except to individuals, corporations, or associations qualified to acquire or hold lands of the public domain, save in cases of hereditary succession). Statutory provision applied: Civil Code, Article 1621 (right of redemption by owners of adjoining rural lands not exceeding one hectare).
Procedural History
Petitioners filed a complaint in the Regional Trial Court of Malolos, Bulacan, challenging the constitutionality and validity of the quitclaim from Helen to David Rey and the subsequent sale to Cataniag, and asserting a right of redemption under Art. 1621. The RTC dismissed the complaint. The Court of Appeals affirmed the RTC decision. Petitioners filed a petition for review under Rule 45 to the Supreme Court, which denied the petition.
Facts
Simeon de Guzman, an American citizen, died circa 1968 leaving properties inherited by his American widow Helen and son David Rey. Helen executed a quitclaim in 1989 assigning her rights in six parcels (including the subject parcel) to her son. The quitclaim was registered and resulted in issuance of a new TCT in David Rey’s name. David Rey sold the parcel in 1991 to Emiliano Cataniag, upon which a TCT in Cataniag’s name was issued. The Halilis, owners of adjoining land, alleged invalidity of the transfers and claimed the right of redemption.
Issues Presented
- Whether the subject land is urban or rural (affecting the availability of the right of redemption under Art. 1621). 2) Whether petitioners can invoke Art. 1621 to redeem the land. 3) Whether the quitclaim from Helen to David Rey — allegedly in violation of the constitutional prohibition on transfer to aliens — should be declared null and void despite the subsequent transfer to a qualified Filipino.
Standard of Review on Factual Findings
The Supreme Court applied the settled rule that factual findings of the trial court, when affirmed by the Court of Appeals, are binding on this Court in a Rule 45 petition except in limited circumstances (e.g., findings based on speculation or conjecture; manifestly mistaken or impossible inferences; grave abuse in appreciation of facts; findings beyond issues or contrary to admissions; conclusions without specific supporting evidence). The Court found no exception applicable to the present case.
Analysis — Land Character (Urban vs. Rural) and Right of Redemption
The trial court’s factual finding that the disputed parcel is urban was supported by clear and convincing evidence: the locality’s development along the national highway (commercial, industrial and residential establishments), presence of factories, warehouses, hospital, gasoline stations, apartment buildings, and commercial stores; a Land Regulatory Board letter classifying the parcel as commercial; and the general trend of development. Because Article 1621 expressly applies only to rural land not exceeding one hectare and requires both the subject land and the adjoining land to be rural, the Court held that petitioners could not invoke the right of redemption. The statutory purpose — to favor agricultural development — would not be served for urban property.
Analysis — Effect of Subsequent Sale to a Qualified Citizen
Although the quitclaim from Helen to her son m
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Case Overview and Disposition
- Petition under Rule 45 seeking review of the Court of Appeals Decision in CA-GR CV No. 37829 promulgated September 14, 1993.
- The dispositive portion of the Court of Appeals decision affirmed the trial court’s dismissal of the complaint for lack of merit.
- The Supreme Court denied the petition and affirmed the Court of Appeals decision, ordering costs against petitioner.
- The Supreme Court emphasized two overarching doctrines: (1) factual findings of a trial court, when affirmed by the Court of Appeals, are generally no longer reviewable by the Supreme Court in a Rule 45 petition; and (2) the transfer of an interest in land to an alien may no longer be assailed on constitutional grounds after the entire parcel has been sold to a qualified citizen.
Facts
- Simeon de Guzman, an American citizen, died circa 1968, leaving real properties in the Philippines.
- His forced heirs were his widow, Helen Meyers Guzman, and his son, David Rey Guzman, both American citizens.
- On August 9, 1989, Helen executed a deed of quitclaim assigning, transferring and conveying to David Rey all her rights, titles and interests in and over six parcels inherited from Simeon, including the parcel at issue.
- The parcel in dispute is situated in Bagbaguin, Sta. Maria, Bulacan, containing 6,695 square meters, originally covered by TCT No. T-170514.
- Upon registration of the quitclaim, TCT No. T-170514 was cancelled and TCT No. T-120259 was issued in David Rey Guzman’s name.
- On February 5, 1991, David Rey Guzman sold the parcel to Emiliano Cataniag; TCT No. T-120259 was cancelled and TCT No. T-130721(M) was issued in Cataniag’s name.
- Petitioners (Celso R. Halili and Arthur R. Halili) own the adjoining lot and filed a complaint challenging the constitutionality and validity of the two conveyances and claiming ownership based on the right of legal redemption under Article 1621 of the Civil Code.
Procedural History
- Petitioners filed suit in the Regional Trial Court (RTC) of Malolos, Bulacan.
- The RTC dismissed the complaint by Decision dated March 10, 1992 (Penned by Judge Valentin R. Cruz).
- Petitioners appealed to the Court of Appeals. The Court of Appeals (Ninth Division: JJ. Cezar D. Francisco, Gloria C. Paras (chairman), and Buenaventura J. Guerrero) promulgated its decision on September 14, 1993 affirming the RTC’s dismissal.
- Petitioners filed a petition for review under Rule 45 to the Supreme Court.
- The Supreme Court considered petitioners’ memorandum and resolved the case in favor of respondents by Decision reported at 350 Phil. 906; 95 OG No. 7, 1071 (February 15, 1999) (G.R. No. 113539, March 12, 1998).
Issues Presented by Petitioners
- Petitioners assigned errors contending that the Court of Appeals:
- Erred in affirming the trial court’s conclusion that the land in question is urban, not rural.
- Erred in denying petitioners’ right of redemption under Article 1621 of the Civil Code.
- Having considered the conveyance from Helen to David Rey illegal, erred in not declaring the same null and void.
Trial Court Findings (as affirmed by the Court of Appeals)
- The subject property is urban in character.
- RTC’s factual finding based on observed surrounding development along Bagbaguin Road: residential, commercial, and industrial establishments; factories; commercial stores; Pepsi-Cola Warehouse; Cruz Hospital; gasoline stations; apartment buildings for commercial purposes; construction firms; predominance of business activity; only a short portion vacant.
- Tax declaration listed the land as agricultural, but the Land Regulatory Board in a letter to Emiliano Cataniag dated October 3, 1991 attested the property as commercial and noted the trend of commercial development; the Board’s classification was based on present condition and community development and was later than the tax declaration.
- The quitclaim executed by Helen was intended to authorize David Rey to dispose of the inherited properties in accordance with the Constitution and laws, not to subvert them.
- Because the subject land was determined to be urban, petitioners could not invoke Article 1621, which presupposes the land sought to be redeemed is rural.
Governing Legal Provision: Article 1621, Civil Code
- Article 1621 text (as cited):
- “The owners of adjoining lands shall also have the right of redemption when a piece of rural land, the area of which does not exceed one hectare, is alienated, unless the grantee does not own any rural land. This right is not applicable to adjacent lands which are separated by brooks, drains, ravines, roads and other apparent servitudes for the benefit of other estates. If two or more adjoining owners desire to exercise the right of redemption at the same time, the owner of the adjoining land of smaller area shall be preferred; and should both lands have the same area, the one who first requested the redemption.”
- Key legal construct:
- Article 1621 requires both the land sought to be redeemed and the adjoining land of the party asserting the right to be rural; if one or both are urban, the right does not apply.
- The provision’s purpose is to favor agricultural development and is limited to rural lands not exceeding one hectare.
First Issue: Urban Character and Right of Redemption — Supreme Court Analysis
- Standard of review on facts:
- Whether land is rural or urban is a factual question generally not reviewable by the Supreme Court when trial court f