Vda. de Panaligan v. CA

G.R. No. 112611 (July 31, 1996)

SC upheld the Superioridad spouses' right to repurchase homestead land without payment tender.

Facts:

The case revolves around a parcel of land measuring 79,509 square meters located in Barrio 5, Norala, South Cotabato, which was originally acquired by spouses Gaudencio Superioridad and Socorro Barrios under Homestead Patent No. V-5988 on August 13, 1956. They were subsequently issued Original Certificate of Title No. P-6776 for the property.

On January 13, 1973, the Superioridad spouses sold the property to Ariston Panaligan and Clara Atong for P25,000.00. A little over a year later, on February 11, 1974, the Panaligans sold the same lot to their four children for the same amount, subdividing it into four lots (Lot Nos. 744-A, 744-B, 744-C, and 744-D), with corresponding transfer certificates of title issued in favor of the children.

On October 20, 1977, the Superioridad spouses filed a complaint for repurchase of the land under Section 119 of Commonwealth Act No. 141 against the Panaligans and their children, who were now the titled owners. The Panaligans countered that the Superioridad spouses had abandoned their right to the property, that there was no valid tender of payment, and that the Superioridad spouses were not genuinely interested in preserving the land for homestead purposes.

The trial court ruled in favor of the Superioridad spouses, allowing them to redeem the property and ordering them to pay the Panaligans P25,000.00 as the repurchase price, along with P15,000.00 for improvements made on the land. The Panaligans appealed to the Court of Appeals, which affirmed the trial court's decision with modifications regarding the payment timeline.

The Panaligans then filed a petition for review, arguing that the right to repurchase had expired and that the Superioridad spouses had failed to tender payment as required.

Legal Issues:

  1. Whether the Superioridad spouses could validly exercise their right to repurchase the property despite the passage of time since the sale.
  2. Whether the requirement of tender of payment was necessary for the exercise of the right of redemption under Section 119 of Commonwealth Act No. 141.
  3. Whether the Superioridad spouses were guilty of laches in asserting their right to repurchase.

Arguments:

  • Petitioners (Panaligans): They contended that the right to repurchase had already expired, as the Superioridad spouses filed their complaint nine years after the expiration of the five-year period provided by law. They also argued that the Superioridad spouses did not make a valid tender of payment and were guilty of laches, having delayed their claim for an unreasonable period.

  • Respondents (Superioridad spouses): They argued that their right to repurchase was still valid as they filed the suit within the five-year period. They contended that tender of payment was not a requisite for exercising their right of redemption under the specific provisions of the law applicable to homestead patents.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition for review, affirming the decision of the Court of Appeals. The Court clarified that the right of repurchase under Section 119 of Commonwealth Act No. 141 does not require tender of payment as a prerequisite for exercising that right. The Court distinguished the case from previous jurisprudence, noting that the applicable law in this instance was specific to land acquired under homestead patents, which has different provisions compared to ordinary land transactions.

The Court emphasized that the filing of a suit to redeem within the five-year period constituted a formal offer to redeem, negating the need for prior tender of payment. The Court also ruled against the claim of laches, stating that the Superioridad spouses acted within the time frame allowed by law and did not delay unreasonably in asserting their rights.

Significant Legal Principles Established:

  1. The right of repurchase under Section 119 of Commonwealth Act No. 141 does not require tender of payment as a condition for its exercise.
  2. Filing a suit for redemption within the statutory period is sufficient to preserve the right of repurchase.
  3. The concept of laches cannot be applied when a party acts within the time limits set by law for asserting their rights.