G.R. No. L-36083 September 5, 1975
Spouses Ramon Doromal, Sr., and Rosario Salas, and Spouses Ramon Doromal, Jr., and Gaudelia Vega, petitioners, vs. Hon. Court of Appeals and Filomena Javellana, respondents.

FACTS

The case involves Lot 3504 in Iloilo, originally owned in common by the Horilleno siblings and Filomena Javellana. In early 1968, the other co-owners, representing a 6/7 share, sold their interest to the Doromal spouses. The deed of sale expressly stated the purchase price as P30,000. However, the Doromals later claimed in court that the true price was P115,250, alleging the lower figure was used to evade taxes. Javellana, the remaining 1/7 co-owner, was not agreeable to the sale and did not sign the power of attorney authorizing it. Within thirty days from her actual discovery of the sale, Javellana formally offered to redeem the property by tendering P30,000 to the Doromals, which they refused. She then filed an action for legal redemption.

ISSUE

The primary issue is whether Javellana, as a co-owner, can validly exercise her right of legal redemption by tendering the price stated in the deed of sale (P30,000), or whether she must pay the alleged higher, actual price (P115,250) that the buyers claim was paid but understated for tax purposes.

RULING

The Supreme Court ruled in favor of Javellana, affirming the Court of Appeals’ decision. She validly exercised her right of redemption by tendering the price stated in the public document—P30,000. The Court held that the redemption price is determined by the consideration stated in the deed of sale, not by any secret or unofficial agreement between the vendor and the vendee. To rule otherwise would allow parties to an illegal contract (tax evasion) to profit from their own wrongdoing by using the courts to enforce an undisclosed price that defrauds the government. The principle of in pari delicto applies; the law will not aid the Doromals in their attempt to benefit from their admitted falsification of the public document. The Doromals, having executed a deed stating a specific price, are estopped from claiming a different amount against the redeeming co-owner who was not a party to their illicit scheme. The redemption right is statutory and must be based on the official record to ensure certainty and prevent fraud. The Court emphasized that tax evasion should be prosecuted, not rewarded, by judicial sanction.