GR L 21677; (June, 1972) (Digest)
G.R. No. L-21677 June 29, 1972
ANTONIO G. DE SANTOS, petitioner-appellant, vs. CITY OF MANILA and ARELLANO UNIVERSITY, INC., respondents-appellees.
FACTS
Petitioner Antonio G. de Santos sought to annul a contract of exchange executed between the City of Manila and Arellano University, Inc. The contract involved the exchange of city-owned lots, including the contested Lot No. 1 (part of a dried estero bed), for university properties needed for the Azcarraga (Recto) Extension project. De Santos, as successor-in-interest to a neighboring lot owner, claimed a right of legal pre-emption or redemption over Lot No. 1, arguing his predecessor had previously proposed a similar land exchange with the city for a different street-widening project.
The City of Manila had prioritized the Azcarraga Extension project over the Legarda Street widening, which formed the basis of de Santos’s predecessor’s proposal. Consequently, the city held the latter proposal in abeyance and proceeded with the exchange with Arellano University. The Court of First Instance and the Court of Appeals ruled against de Santos, prompting this appeal.
ISSUE
The core issue is whether de Santos possesses a valid right of legal pre-emption or redemption over the city-owned Lot No. 1, entitling him to annul the contract of exchange between the City of Manila and Arellano University.
RULING
The Supreme Court affirmed the lower courts’ decisions, ruling that de Santos had no such right. The legal logic is twofold. First, a right of legal redemption or pre-emption must be grounded in a clear legal provision or an established juridical relation, such as co-ownership. De Santos, a mere adjoining owner, failed to establish any such legal basis granting him a preferential right over the city’s property. His claim, derived from his predecessor’s unaccepted proposal for a different public project, remained a mere offer that never materialized into a vested right.
Second, for a non-party to a contract to seek its annulment, he must demonstrate a direct prejudice to his own rights. Since de Santos possessed no enforceable right of pre-emption or redemption, the contract of exchange caused him no legal detriment. The Court also upheld the award of attorney’s fees to Arellano University, finding the action unfounded and the award within the trial court’s discretion. Thus, the contract was valid and binding against de Santos’s claims.