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TL;DR — Ruling
WHEREFORE, and upon all the foregoing, the Decision of the court below dated March 10, 1992 dismissing the complaint for lack of merit is AFFIRMED without pronouncement as to costs.” The Facts The factual antecedents, as narrated by Respondent Court, are not disputed by the parties. We reproduce them in part, as follows: “Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the Philippines.
WHEREFORE, and upon all the foregoing, the Decision of the court below dated March 10, 1992 dismissing the complaint for lack of merit is AFFIRMED without pronouncement as to costs. The Facts The factual antecedents, as narrated by Respondent Court, are not disputed by the parties. We reproduce them in part, as follows: Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the Philippines. His forced heirs were his widow, defendant appellee [herein private respondent] Helen Meyers Guzman, and his son, defendant appellee [also herein private respondent] David Rey Guzman, both of whom are also American citizens. On August 9, 1989, Helen executed a deed of quitclaim (Annex A-Complaint), assigning[,] transferring and conveying to David Rey all her rights, titles and interests in and over six parcels of land which the two of them inherited from Simeon. Among the said parcels of land is that now in litigation, x x x situated in Bagbaguin, Sta. Maria, Bulacan, containing an area of 6,695 square meters, covered by Transfer Certificate of Title No. T-170514 of the Registry of Deeds of Bulacan. The quitclaim having been registered, TCT No. T-170514 was cancelled and TCT No. T-120259 was issued in the name of appellee David Rey Guzman. On February 5, 1991, David Rey Guzman sold said parcel of land to defendant-appellee [also herein private respondent] Emiliano Cataniag, upon which TCT No. T-120259 was cancelled and TCT No. T-130721(M) was issued in the latters name. [4] Petitioners, who are owners of the adjoining lot, filed a complaint before the Regional Trial Court of Malolos, Bulacan, questioning the constitutionality and validity of the two conveyances -- between Helen Guzman and David Rey Guzman, and between the latter and Emiliano Cataniag -- and claiming ownership thereto based on their right of legal redemption under Art. 1621 [5] of the Civil Code. In its decision [6] dated March 10, 1992, [7] the trial court dismissed the complaint. It ruled that Helen Guzmans waiver of her inheritance in favor of her son was not contrary to the constitutional prohibition against the sale of land to an alien, since the purpose of the waiver was simply to authorize David Rey Guzman to dispose of their properties in accordance with the Constitution and the laws of the Philippines, and not to subvert them. On the second issue, it held that the subject land was urban; hence, petitioners had no reason to invoke their right of redemption under Art. 1621 of the Civil Code. The Halilis sought a reversal from the Court of Appeals which, however, denied their appeal. Respondent Court affirmed the factual finding of the trial court that the subject land was urban. Citing Tejido vs. Zamacoma [8] and Yap vs. Grageda, [9] it further held that, although the transfer of the land to David Rey may have been invalid for being contrary to the Constitution, there was no more point in allowing herein petitioners to recover the property, since it
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