Falcasantos v. How Suy Ching
REITERATIONFacts
The Antecedents: Dalmacio Falcasantos instituted an action for legal redemption against How Suy Ching, administratrix of the estate of the deceased Tan Kiok. The complaint alleged that Lots Nos. 154 and 52 were co-owned by Leonarda Falcasantos, Dalmacio Falcasantos, and Josefa Falcasantos. On December 1, 1934, Leonarda Falcasantos sold her rights to Tan Kiok for P420, an unregistered sale. Dalmacio Falcasantos offered to redeem the property from the defendant for P420, but the defendant refused. Procedural History: The parties submitted the case on the pleadings without adducing evidence. The Court of First Instance of Zamboanga rendered judgment in favor of the plaintiff, ordering the defendant to convey Tan Kiok's rights upon payment of P420. The defendant appealed. The Petition: The defendant appealed the decision, arguing that the plaintiff's right of legal redemption was barred by Article 1524 of the Old Civil Code because the plaintiff had knowledge of the sale long before nine days prior to the filing of the complaint.
Issue(s)
Whether the plaintiff's right of legal redemption was barred by Article 1524 of the Old Civil Code. Whether submitting the case on the pleadings without evidence constitutes an admission of the opposing party's material allegations.
Ruling
The Supreme Court reversed the decision of the lower court and dismissed the complaint. The Court held that the plaintiff's right of legal redemption was lost because he had knowledge of the sale long before nine days prior to the filing of the complaint. Furthermore, the Court found the complaint fatally defective for failing to allege that the offer to redeem was made within the prescribed period.
Ratio Decidendi
On the issue of knowledge of the sale and the nine-day period for legal redemption: The Court reiterated the rule that under Article 1524 of the Old Civil Code, the right of legal redemption must be exercised within nine days from the inscription in the Registry, or, in the absence thereof, from the time the redemptioner has had knowledge of the sale. The Court emphasized that the starting point of the nine-day period is either registration or, in its absence, actual knowledge of the conveyance by the co-owners. The Court cited Manresa, stating that the phrase "in the absence of registration" refers to cases where registration is not possible, such as with personal property, or where the purchaser fails to register the conveyance. In this case, the plaintiff was deemed to have had knowledge of the sale long before nine days prior to the filing of the complaint, thus losing his right of legal redemption. On the effect of submitting the case on the pleadings: The Court applied the established rule that a party who prays for judgment on the pleadings without offering proof admits the truth of all material and relevant allegations of the opposing party. Since the parties submitted the case on the pleadings without introducing evidence, the plaintiff was considered to have admitted the material allegation in the defendant's answer that he had known of the sale long before nine days prior to the filing of the complaint. The Court clarified that while new matters in an answer are generally deemed controverted if no reply is filed, this rule does not apply to cases submitted on the pleadings, where the opportunity to prove or disprove facts is mutual during a regular trial.
Main Doctrine
The nine-day period for legal redemption under Article 1524 of the Old Civil Code, in the absence of registration, is counted from the time the redemptioner has actual knowledge of the sale. A party who submits a case on the pleadings without adducing evidence is deemed to admit the material allegations of the opposing party's pleading.