Case Summary (G.R. No. L-48457)
Background of the Case
The case originated from a dispute over a parcel of land originally part of a larger estate owned by the spouses Crispulo Manlapaz and Antonia Villanueva. Following their deaths, their children, including Ernesta Manlapaz-Valdemoro, extrajudicially partitioned the land. Petitioner Perla Hernandez purchased a portion from one of the siblings, Sancho Manlapaz. Ernesta, claiming she was not informed of the sale, filed a complaint for legal redemption, seeking to reclaim the lot based on her status as a co-owner.
Trial Court's Findings
The trial court ruled in favor of Ernesta, granting her the right to redeem the property based on Articles 1620 and 1623 of the Civil Code, which pertain to the rights of co-owners. The court found that despite the partition, Ernesta retained co-ownership, allowing her the right to redeem the property.
Arguments by the Petitioner
Perla Hernandez contested the trial court’s decision, asserting that the prior extrajudicial partition extinguished any co-ownership the parties had in the property, thus voiding Ernesta’s claim for legal redemption under Article 1620. Petitioner argued that the relationship of co-ownership no longer existed after the partition, making the right to redemption invalid.
Court's Analysis of Co-Ownership
The Supreme Court examined the legal foundations of co-ownership and the applicability of Articles 1620 and 1623. The Court identified that co-ownership is characterized by undivided ownership among different individuals. Citing previous rulings, the Court clarified that once a property is partitioned and ownership is concretely defined, co-ownership ceases, and thus, the right of redemption cannot be invoked.
Precedents and Legal Principles
The Court referenced relevant cases, such as De la Cruz v. Cruz and Caro v. Court of Appeals, which established that the right of legal redemption is tied to the continuous existence of co-ownership. The right is designed to minimize the number of co-owners and does not extend once the property has been partitioned and individual rights to the property have been established.
Respondent's Contentions on Adjoining Owner Rights
Respondent Ernesta attempted to reframe her argument by citing Article 1622, claiming she was entitled to pre-emption as an adjoining owner. However, the Supreme Court determined that she failed to demonstrate essential elements of this claim, notably the requirement that the property be "about to be resold" or that such a resale had already been finalized.
Assessment of Appeal Timeliness
Ernesta raised an argument concerning the timeliness of filing the record on appeal, assertin
...continue readingCase Syllabus (G.R. No. L-48457)
Case Background
- This case arises from a petition for review on certiorari filed by defendant Perla Hernandez, challenging a decision by the Court of First Instance of Masbate, Branch II.
- The trial court's decision allowed plaintiff Ernesta Manlapaz-Valdemoro to exercise her right of legal redemption over a parcel of land.
- The disputed property, measuring 46.40 square meters, was sold to Hernandez by Sancho Manlapaz for P3,000.00.
Factual Antecedents
- The land in question was part of a larger parcel originally owned by spouses Crispulo Manlapaz and Antonia Villanueva.
- Following the death of the spouses, their children, including Ernesta and Sancho, partitioned the land extrajudicially on December 30, 1974.
- Sancho sold the lot adjudicated to him to Hernandez on March 8, 1975. Ernesta purchased an adjacent lot from her brother Jose on April 8, 1975.
- On April 29, 1975, Ernesta filed a complaint for redemption, claiming she was not informed of Sancho’s sale to Hernandez.
Trial Court Proceedings
- The trial court found Ernesta to be a co-owner and allowed her to redeem the property, ordering Hernandez to resell it for P3,000.00.
- The court based its decision on Articles 1620 and 1623 of the Civil Code, which pertain to the right of redemption for co-owners.
Legal Issues
- The primary legal issue focuses on whether Ernesta retained her right of legal redemption after the property had been extrajudicially partitioned among the heirs.
- Hernandez argued that the partition extinguished any co-ownership a