Mendoza I v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners, heirs of the late Arcadio Mendoza, filed an action for reconveyance of real property against respondents spouses Renato and Lucia Samonte. They alleged that if the sale of Lot 3-A by petitioner Trinidad Manuel Mendoza to respondents is declared valid, they are still entitled to legal redemption. Procedural History: The Court of First Instance of Bulacan dismissed the complaint, finding that the "Dokumento ng Bilihan" evidenced an agreement to partition the properties of Arcadio Mendoza, adjudicating Lot 3-A to Trinidad Manuel Mendoza. The Court of Appeals affirmed this decision, and its resolution denying reconsideration was also affirmed. The Petition: Petitioners seek to nullify the decision of the Court of Appeals, arguing that the "Dokumento ng Bilihan" is void because Lot 3-A was still under litigation when it was executed, and Trinidad Manuel Mendoza was only entitled to a 1/13 share, not the entirety of Lot 3-A. They contend that the remaining petitioners can still exercise the right of legal redemption.
Issue(s)
Whether the "Dokumento ng Bilihan" is valid. Whether petitioners can still exercise the right of legal redemption.
Ruling
The petition is denied. The decision dated June 23, 1976, and the resolution dated September 15, 1976, of the Court of Appeals are affirmed.
Ratio Decidendi
On the validity of the "Dokumento ng Bilihan": The Court affirmed the lower courts' findings that the "Dokumento ng Bilihan" is a valid document. The existence of a partition agreement was evidenced by the "Dokumento ng Bilihan" itself, which clearly stated that Lot 3-A was adjudicated to Trinidad Manuel Mendoza and Lot 3-B to the children. This partition was further supported by the subdivision plan of Lot 3, approved by the Commissioner of Land Registration. The Court also considered the presumption that the signatories understood the contents of the deed they signed, especially since it was written in Tagalog, a dialect known to them. Furthermore, the actions of the respondents in building their house on the lot without objection from the petitioners indicated their knowledge and acceptance of the sale. The principle of estoppel was applied against the petitioners who participated in or benefited from the sale. On the right of legal redemption: The Court ruled that petitioners cannot exercise the right of legal redemption because the co-ownership over Lot 3 had already been extinguished by the partition. Article 1620 of the Civil Code, which grants the right of legal redemption to a co-owner, applies only when co-ownership still exists. Since Lot 3 was subdivided into Lot 3-A and Lot 3-B, and Lot 3-A was adjudicated to Trinidad Manuel Mendoza, it was no longer held in co-ownership by the heirs at the time of its sale to the respondents. Therefore, the right of legal redemption under Article 1620 was not applicable in this case.
Main Doctrine
The right of legal redemption under Article 1620 of the Civil Code applies only when co-ownership still exists. If the property has been partitioned or an identified share has been sold, there is no longer any right of legal redemption.