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Halili Vs CA

The Supreme Court ruled that there was no ambiguity in Article 1621 of the Civil Code regarding the right of legal redemption. Article 1621 clearly states that this right applies only to rural lands that are less than 1 hectare in size. The land in question was found to be urban, not rural, so the plaintiffs had no right to invoke legal redemption under Article 1621. The court dismissed the complaint challenging the validity of the two conveyances of the urban land between the parties.

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188 views2 pages

Halili Vs CA

The Supreme Court ruled that there was no ambiguity in Article 1621 of the Civil Code regarding the right of legal redemption. Article 1621 clearly states that this right applies only to rural lands that are less than 1 hectare in size. The land in question was found to be urban, not rural, so the plaintiffs had no right to invoke legal redemption under Article 1621. The court dismissed the complaint challenging the validity of the two conveyances of the urban land between the parties.

Uploaded by

Glenn Fortes
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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CELSO R. HALILI vs.

COURT OF APPEALS

FACTS:

Simeon de Guzman, an American citizen, died sometime in 1968, leaving real


properties in the Philippines. His forced heirs were his widow, Helen Meyers Guzman, and his
son, David Rey Guzman, both of whom are also American citizens. On August 9, 1989, Helen
executed a deed of quitclaim, assigning, transferring and conveying to David Rey all her rights,
titles and interests in and over six parcels of land which the two of them inherited from Simeon.

Among the said parcels of land is that now in litigation, x x x situated in Bagbaguin,
Sta. Maria, Bulacan. The quitclaim having been registered, TCT No. T-170514 was cancelled and
TCT No. T-120259 was issued in the name of appellee David Rey Guzman.

On February 5, 1991, David Rey Guzman sold said parcel of land to Emiliano Cataniag,
upon which TCT No. T-120259 was cancelled and TCT No. T-130721(M) was issued in the latters
name.

Petitioners, who are owners of the adjoining lot, filed a complaint before the Regional
Trial Court of Malolos, Bulacan, questioning the constitutionality and validity of the two
conveyances -- between Helen Guzman and David Rey Guzman, and between the latter and
Emiliano Cataniag -- and claiming ownership thereto based on their right of legal redemption
under Art. 1621 of the Civil Code.
In its decision, the trial court dismissed the complaint. The Halilis sought a reversal
from the Court of Appeals which, however, denied their appeal. Hence, this petition.

ISSUE:
Whether there is ambiguity in Article 1621 of the Civil Code

RULING/HELD:

The Supreme Court held that:

No there is no ambiguity.
In view of the finding that the subject land is urban in character, petitioners have indeed no
right to invoke Art. 1621 of the Civil Code, which presupposes that the land sought to be
redeemed is rural. The provision is clearly worded and admits of no ambiguity in construction:
ART. 1621. The owners of adjoining lands shall also have the right of redemption
when a piece of rural land, the area of which does not exceed one hectare, is alienated,
unless the grantee does not own any rural land.

Under this article, both lands -- that sought to be redeemed and the adjacent lot belonging
to the person exercising the right of redemption -- must be rural. If one or both are urban, the
right cannot be invoked. The purpose of this provision which is limited in scope to rural lands not
exceeding one hectare, is to favor agricultural development. The subject land not being rural and,
therefore, not agricultural, this purpose would not be served if petitioners are granted the right
of redemption under Art. 1621. Plainly, under the circumstances, they cannot invoke it.

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