Petitioner
Primary Structures Corp. Represented Herein By Its President Engr. William C. Liu
Respondent
Sps. Anthony S. Valencia
Citation
G.R. No. 150060
Court
Supreme Court
Division
First Division
Ponente
Vitug, J.
Decided
August 19, 2003

Summary

Primary Structures Corp. sought to exercise legal redemption over three rural lots sold by Hermogenes Mendoza to the Valencia spouses in 1994. The company, owning an adjacent lot, learned of the sale only in 1996 and immediately claimed redemption rights under Articles 1621 and 1623 of the Civil Code. The RTC and CA denied the claim, but the Supreme Court reversed, ruling that the mandatory written notice required by Article 1623 was never properly given to the petitioner. The Court emphasized that actual knowledge does not substitute for written notice, and statements in deeds of sale cannot replace the statutory requirement for direct written notice to possible redemptioners. The decision reinforced the strict compliance requirement for legal redemption procedures in rural land transactions.

Statutes applied

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By Intellegal Editorial Board · August 19, 2003

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