G.R. No. L-66101 November 21, 1984
SPOUSES JOSE FABIA and ANITA FABIA, petitioners, vs. INTERMEDIATE APPELLATE COURT, ANGEL MARARAC and REMEDIOS ALEJANDRO, EUGENIO, GILDO and ROMEO, ALL SURNAMED MARARAC, represented by their mother CARLINA RAFANAN, respondents.

FACTS

The respondents, owners of an adjoining lot, sought to legally redeem a parcel of land sold to the petitioners, invoking Article 1621 of the Civil Code, which grants a right of redemption to owners of adjoining rural lands. The land in question was sold to the petitioners in 1975. The parties submitted a stipulation of facts, which established that the respondents reside on the lot adjacent to the subject property. The southern boundary of the subject land is a barrio road, and the area along this road features houses, a chapel, and a school. The subject land itself is fenced and contains fruit trees, banana plants, and a fishwell.
The trial court ruled in favor of the petitioners, finding that the respondents failed to prove the land was rural. The court noted the complaint described the land as “residential,” the surrounding area was developed, and the presence of trees and plants is typical for a Philippine residence. The Intermediate Appellate Court reversed this decision, ordering the respondents allowed to redeem the property. The petitioners elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the respondents have a right of legal redemption under Article 1621 of the Civil Code, which requires the subject land and the adjoining land to be rural.

RULING

The Supreme Court granted the petition, reversing the Appellate Court and reinstating the trial court’s judgment. The legal logic is anchored on the specific requisites of Article 1621. For the right of legal redemption to apply, both the land sought to be redeemed and the adjoining land of the redemptioner must be rural or agricultural. The Court examined the factual circumstances to determine the land’s character. The subject land is situated in a barangay area with a road, lines of houses, a chapel, and a school along its boundary. While it contains trees and a fishwell, the Court reasoned that a residential lot is not converted to agricultural use merely by having plants or garden crops, as these are typical for a Philippine home lot. Conversely, the stipulation of facts explicitly states the respondents “reside on” the adjoining lot, which is an admission of its residential character. Since the adjoining land is not rural, a fundamental requirement of Article 1621 is absent. Therefore, the respondents have no right to redeem the property. The purpose of the law—to consolidate small agricultural holdings—is not served when the adjoining land is residential.