GR L 12188; (November, 1917) (Digest)
G.R. No. L-12188, November 9, 1917
MARCIANO ESPIRITU, as administrator of the intestate estate of Jayme Espiritu, plaintiff-appellant, vs. SANTIAGO DE GUZMAN, ET AL., defendants-appellees.
FACTS:
Marciano Espiritu, as the judicial administrator of the estate of his deceased brother Jayme Espiritu, filed an action to redeem a parcel of land. During his lifetime, Jayme Espiritu had given the land in antichresis (as security for a loan) to Santiago de Guzman for a loan of P100. After Jayme’s death, his widow, Valentina Guevara, executed an absolute deed of sale (Exhibit 2) over the same land in favor of Juana de Guzman (Santiago’s daughter) for the price of P400. Juana de Guzman was in possession of the land. The plaintiff administrator contended that the land was the exclusive property of the deceased Jayme Espiritu, having been acquired by him from Angel Mendoza in exchange for a carabao. The Court of First Instance of Bulacan dismissed the complaint.
ISSUE:
Whether the plaintiff-administrator is entitled to redeem the land from the defendants, given the subsequent absolute sale of the property by the widow of the deceased to a third party (Juana de Guzman).
RULING:
No. The Supreme Court affirmed the dismissal of the complaint. The Court found as an incontrovertible fact that Juana de Guzman was in possession of the land as an absolute purchaser from Valentina Guevara for a valuable consideration of P400, as evidenced by a public instrument (Exhibit 2) and corroborated by testimony. The Court noted that the document of absolute sale (Exhibit 1) from the original owners, Angel Mendoza and his wife, was in favor of “Jayme Espiritu and his wife Valentina Guevara,” thereby disproving the claim that the land was the deceased’s exclusive property. The Court declined to rule on the extent of the widow’s capacity to sell (i.e., whether she could sell the whole or only half) as she was not a party to the action, and the rescission of her sale was not sought. Therefore, the action for redemption could not prosper.
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