Teodoro Rabago Baltazar v. Rolando V. Miguel

Summary

This case involves the right of legal redemption under Articles 1620 and 1623 of the Civil Code. Co-owner Baltazar sought to redeem property sold by his co-owners to Miguel without written notice. The RTC and CA dismissed the action, finding failure to timely consign the redemption price. However, the Supreme Court reversed, holding that Miguel waived his right to challenge non-compliance with the condition precedent by not raising it in his answer and waiting over 10 years to file a Motion to Dismiss. The Court distinguished between prescription and condition precedent, emphasizing that failure to consign redemption price is merely procedural, not jurisdictional. The doctrine of laches was applied against Miguel for his unreasonable delay. The case clarifies that actual knowledge of sale can substitute for written notice, but procedural defenses must be timely raised or they are waived.