Title
Tabigue vs. Green
Case
G.R. No. 4277
Decision Date
Aug 18, 1908
Plaintiff retained redemption rights despite executing a second deed; defendant's conveyance to military government did not override prior agreement. Supreme Court upheld trial court's decision.

Case Summary (G.R. No. 4277)

Primary Facts

On February 1, 1906, the plaintiff sold the property to the defendant through an absolute deed, yet retained the right to redeem the property within a specified timeframe, as stipulated in the deed. At the time of sale, a case was pending in the Court of Land Registration concerning the property. On October 20, 1906, the defendant communicated with a witness, making several notable statements regarding the plaintiff’s rights and the upcoming decree from the Land Court favoring the plaintiff. The defendant indicated that upon registration, a new deed would be required, and he offered a potential extension for redemption within three months despite the original expiration.

Land Registration Progress

The Court of Land Registration ultimately ruled in favor of the plaintiff, with the property being registered in her name on December 15, 1906. Subsequently, the plaintiff executed an absolute deed conveying the property back to the defendant on December 16, 1906, who, in turn, obtained a new certificate of ownership confirming him as the sole owner. However, prior to executing the deed, the plaintiff had received and retained the defendant’s letter detailing her redemption rights.

Dispute Over Redemption Rights

The core of the dispute revolved around whether the plaintiff voluntarily waived her right to redeem at the time of the final deed execution. The defendant’s witnesses claimed she had waived that right and indicated an expectation to receive compensation upon any future sale to the military government. Conversely, the plaintiff and her witness denied any waiver and affirmed her intent to exercise her right to redeem the property by offering the original consideration amount of P1,900.

Judicial Offer and Refusal

On December 22, 1906, the plaintiff’s attorney formally submitted an offer to redeem the property, which the defendant refused. Subsequently, on December 24 or 25, 1906, the defendant conveyed the land to the military government for P3,000 in anticipation of approval from military authorities, which was unsubstantiated due to the lack of evidence regarding such approval or payment.

Trial Court's Decision

The trial court ruled in favor of the plaintiff, recognizing her right to redeem the property. The court determined that the evidence did not preponderate against its decision, affirming the plaintiff's claim. Section 50 of Act No. 496 was pivotal, as it clarifies that a regi

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