15/05/2026
“No written notice” does not always save a redemption claim.
In Azurin, Jr. v. Chua, the Supreme Court denied a co-owner’s attempt to redeem property after waiting more than 6 years to act.
The petitioners argued that the 30-day period under Article 1623 of the Civil Code never started because they were never formally notified in writing about the sale.
Normally, written notice is required.
But the Court said the surrounding facts already showed that they knew about the transaction long before filing the case.
The property had already been subdivided. A separate title had already been issued in the buyer’s name. There was even an earlier recovery of possession case filed against them.
Despite all these, they still waited years before asserting their redemption rights.
The Supreme Court applied the doctrine of laches — equity does not help those who sleep on their rights.
The Court also clarified that Alonzo v. IAC did not remove the written notice requirement. It only recognized that, in exceptional situations, actual knowledge plus unreasonable delay may make strict compliance inequitable.
Practical takeaway:Even if the law appears to support your position, delay can still defeat your claim.