G.R. No. 26867 - People vs. De Leon

Case Summary (G.R. No. 26867)

Factual Background

The property in dispute was one of three lots inherited by the heirs of Cenon Manaois. By a public deed of partition (Exhibit "1") executed on January 10, 1943, the heirs divided the lot described in the complaint among themselves. Under that partition, Gregorio Manaois received one-fourth of the lot toward its southeastern side; Florencio Manaois received one-fourth toward its southwestern side; Francisca de Guzman received one-eighth toward the north; Leonora Manaois received one-eighth toward the northeastern side; and Inocencia Manaois received one-eighth toward the northwestern side. After the deed, each heir took possession of the portion adjudicated to him or her.

Subsequently, on April 2, 1943, Florencio Manaois sold his one-fourth share to respondent Jose Zamora for P500, executing the corresponding public deed of conveyance (Exhibit "2"). Zamora then took possession of the land conveyed in the presence of and with the acquiescence of Gregorio Manaois, as well as the brothers-in-law of Leonora Manaois and Inocencia Manaois, namely Miguel Fabia and Crescendo Rosario.

After the sale, Zamora sought the certificate of title covering the property. On April 30, 1943, he went to the law firm De la Pena Cruz, Arboleda and Peña in Lingayen, Pangasinan, where he learned that Attorney Arboleda would release the certificate only if Zamora brought at least one child of Cenon Manaois and paid P45 for an amount allegedly owed to the firm by the deceased. Zamora returned and sought the attendance of Inocencia, Juliana, and Leonora Manaois, who refused and directed him to Gregorio Manaois. Gregorio agreed to accompany Zamora. On May 1, 1943, upon payment of P45, Attorney Arboleda executed the necessary deed of release and instructed both Zamora and Gregorio Manaois to record it so that they could obtain the certificate of title of the property of Cenon Manaois. On May 3, 1943, Zamora and Gregorio presented the deed of release for record and paid the required fees, after which they were given the owner’s duplicate of two certificates of title. Zamora retained the title covering his property, specifically the owner’s duplicate of certificate of title No. 52914, and gave the other duplicate to Gregorio.

Once Zamora had the owner’s duplicate of certificate of title No. 52914, he presented the deed of conveyance for registration. The registry advised that the deed could not be recorded unless a copy of the deed of partition among the heirs of Cenon Manaois was also submitted. Because Zamora encountered difficulties in securing that partition deed copy, he initially did not insist on recording the conveyance.

On July 22, 1943 (as reflected in the narration by the Court of Appeals), Zamora returned to the registry of deeds and again presented the deed of conveyance, explaining why he had not earlier submitted the deed of partition. The registry accepted the deed and entered it in the entry book of the office. On July 22, 1946, the plaintiffs commenced the present action for legal redemption under Articles 1523 and 1524 of the old Civil Code.

Trial Court and Court of Appeals Rulings

The petitioners lost in the Court of First Instance of Pangasinan. They also lost on appeal in the Court of Appeals. The Court of Appeals held that the deed conveying the land to respondent Jose Zamora was registered on July 22, 1946, coinciding with the commencement of the action. The appellate court further found that the evidence clearly showed that the plaintiffs had knowledge of the sale from its execution on April 2, 1943.

The Parties’ Contentions

The petitioners acknowledged the controlling provision, Article 1524 of the old Civil Code, which provides that the right of legal redemption “can be exercised only within nine days, counted from the inscription in the registry, and in the absence thereof from the time the redemptioner shall have had knowledge of the sale.” The petitioners accepted that the case turned solely on when the nine-day period began. They framed the question as whether it was to be counted from July 22, 1946 (the date of registration), or from April 2, 1943 (the time when they had actual knowledge of the sale).

The Court of Appeals sustained the view that the start date was the date of actual knowledge, April 2, 1943. Petitioners implicitly opposed that view by urging that the redemption period should instead be counted from the date of registration, July 22, 1946.

Legal Basis and Reasoning

The Court agreed with the Court of Appeals. It adopted the rationale previously laid down by the Supreme Court of Spain interpreting similar provisions regarding redemption periods in relation to registration and knowledge.

The Court explained that the Spanish Supreme Court, in decisions dated December 14, 1905 and June 30, 1910, held that the date of registration was intended to apply only to cases where the date of actual knowledge could not be established. The underlying principle was that knowledge of the sale may be presumed from its registration, but such presumption should not be treated as controlling where actual knowledge is already determined by evidence. Otherwise, the Court observed, a conclusive legal presumption based on registration would be given greater weight than the real fact of actual knowledge.

To support that interpretation, the Court quoted and relied on the commentary of Manresa, explaining that the Civil Code did not intend to impose for all cases a uniform nine-day redemption period counted from registration. Rather, it applied that uniform counting only where it was not possible to prove whether the redemptioner had prior knowledge of the sale. In such cases, the law established a presumption juris et de jure based on registry publicity. However, when the redemptioner did know of the sale, the period should be counted f

Case Syllabus (G.R. No. 26867)

The case arose from a dispute over legal redemption of real property sold by Florencio Manaois to Jose Zamora.
The plaintiffs in the trial court were Leonora Manaois, Gregorio Manaois, Juliana Manaois, and Inocencia Manaois, who are the petitioners before the Supreme Court.
The defendants were Jose Zamora and others named as respondents, who opposed the redemption suit.

Parties and Procedural Posture

The petitioners filed an action for legal redemption under Articles 1523 and 1524 of the old Civil Code.
The Court of First Instance of Pangasinan dismissed the complaint.
The petitioners appealed to the Court of Appeals, which likewise ruled against them.
The petitioners then elevated the case to the Supreme Court via review by certiorari.
The Supreme Court limited the controversy to the proper computation of the nine-day redemption period under Article 1524 of the old Civil Code.

Key Factual Allegations

The parties were heirs who had inherited pro-indiviso ownership of a rural parcel of land in Lomboy, Binmaley, Pangasinan, with an area of 18,975 square meters, from Cenon Manaois.
In a partition recorded in a public deed (Exhibit “1”), the lot was adjudicated among heirs in the following proportions: one-fourth to Gregorio Manaois, one-fourth to Florencio Manaois, one-eighth to Francisca de Guzman, one-eighth to Leonora Manaois, and one-eighth to Inocencia Manaois.
After the partition, each heir took possession of the portion adjudicated to him or her.
On April 2, 1943, Florencio Manaois sold and conveyed his one-fourth share to Jose Zamora for P500, executing a public deed of conveyance (Exhibit “2”).
After the deed of sale was executed, Zamora took possession of the property in the presence and with the acquiescence of Gregorio Manaois and the husbands of Leonora Manaois and Inocencia Manaois.
On April 30, 1943, Zamora went to a law firm to secure the certificate of title covering the property, and was told that at least one child of Cenon Manaois had to appear and that the amount of P45 owed to the firm had to be paid.
Zamora returned and requested Inocencia and Juliana (and Leonora, as appears in the narration) to accompany him, but they refused and referred him to Gregorio.
On May 1, 1943, when Gregorio accompanied Zamora, the lawyer executed a deed of release after Zamora paid P45, and instructed them to record it for the issuance of the relevant certificates of title.
Zamora and Gregorio presented the deed of release for record on May 3, 1943, and they were given the owner’s duplicate of two certificates of title, with Zamora retaining owner’s duplicate of certificate of title No. 52914.
Upon obtaining the duplicate title, Zamora attempted to present the deed of conveyance for recording, but was advised that recording required a copy of the partition deed among Cenon Manaois’s heirs.
Zamora did not insist at that time due to the difficulties he encountered in securing the partition deed copy.
Zamora later returned to the office of the register of deeds and on July 22, 1946, presented the deed of conveyance for record, explaining why he previously could not submit the partition deed.
The register of deeds accepted and entered the deed in its entry book on July 22, 1946.
On July 22, 1946, the petitioners commenced the redemption acti