Leonardo Mariano v. Hon. Court of Appeals

Summary

This case involves a property dispute among co-heirs of Francisco Gosiengfiao's intestate estate over a residential lot in Tuguegarao, Cagayan. After the property was foreclosed by the Rural Bank, one co-heir (Amparo) redeemed it using her personal funds and subsequently sold it to Leonardo Mariano in 1966. Other co-heirs learned of the sale in 1982 and filed suit for recovery and legal redemption. The Supreme Court affirmed the Court of Appeals ruling that redemption by one co-owner inures to the benefit of all co-owners and does not terminate co-ownership. The Court clarified the crucial distinction between Articles 1088 and 1620 of the Civil Code and emphasized that written notice is mandatory for legal redemption. Since no written notice was provided to the co-heirs regarding the 1966 sale, their redemption period never commenced, preserving their right to redeem. This decision reinforces important principles of succession law, co-ownership rights, and procedural requirements for legal redemption in Philippine property law.