GR L 73451; (March, 1988) (Digest)
G.R. No. L-73451 March 28, 1988
JUANITA YAP SAY and WILLIAM LIM, petitioners, vs. INTERMEDIATE APPELLATE COURT, CHATEAU DE MANILA DEVELOPMENT CORPORATION, and EMILIANA VILLAMAYOR DE LA COSTA, respondents.
FACTS
The original plaintiffs, spouses Trinidad Laborde and Tan Lo, filed a complaint for legal redemption and rescission of a contract of sale over a land and warehouse against the vendor, Emiliana de la Costa, and the vendee, Chateau de Manila Development Corporation. Petitioners Juanita Yap Say and William Lim subsequently filed a complaint in intervention, claiming that as tenants of a portion of the subject premises, they possessed a right of legal redemption under Presidential Decree No. 1517, the Urban Land Reform Law. The private respondents moved to dismiss the complaint in intervention, arguing it stated no cause of action and was barred by laches or waiver.
The trial court granted the motion to dismiss. The intervenors’ motion for reconsideration was denied. They then appealed to the Intermediate Appellate Court, which denied their appeal. The original plaintiffs’ separate petition for review to the Supreme Court was earlier denied for lack of merit. The intervenors, now the petitioners, elevated their case, contending they were denied procedural due process.
ISSUE
Whether the petitioners were denied procedural due process and whether they have a valid cause of action for legal redemption under P.D. No. 1517.
RULING
The Supreme Court affirmed the decision of the Intermediate Appellate Court, ruling against the petitioners on both procedural and substantive grounds. On the procedural issue, the Court found no denial of due process. The petitioners were allowed to intervene over opposition, filed a complaint in intervention, and were heard in both the trial and appellate courts through their various pleadings. The Court emphasized that the opportunity to be heard, a core component of due process, is satisfied not only by oral arguments but also through the submission of pleadings. Since petitioners availed themselves of these procedural avenues, their claim of a due process violation was unfounded.
On the merits, the Court upheld the dismissal for failure to state a cause of action. The right of first refusal under Section 6 of P.D. No. 1517 applies only within declared “Urban Land Reform Zones” or specific sites proclaimed for urban land reform. The petitioners failed to allege, and the records did not show, that the poblacion of Mauban, Quezon, where the property was located, had been so declared or proclaimed. Absent this essential jurisdictional fact, the legal redemption right under the decree does not arise. Consequently, their complaint in intervention correctly failed to state a cause of action. The petition was denied.