Estrella vs. Francisco (GR No. 209384 June 27, 2016) PDF

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8/30/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 794

G.R. No. 209384. June 27, 2016.*

URBANO F. ESTRELLA, petitioner, vs. PRISCILLA P.


FRANCISCO, respondent.

Agrarian Reform; Social Justice; The State adopts a policy of


promoting social justice, establishing owner cultivatorship of economic-size
farms as the basis of Philippine agriculture, and providing a vigorous and
systematic land resettlement and redistribution program.—The use and
ownership of property bears a social function, and all economic agents are
expected to contribute to the common good. To this end, property ownership
and economic activity are always subject to the duty of the State to promote
distributive justice and intervene when the common good requires. As early
as 1973, the Philippines has already declared our goal of emancipating
agricultural tenants from the bondage of the soil. The State adopts a policy
of promoting social justice, establishing owner cultivatorship of economic-
size farms as the basis of Philippine agriculture, and providing a vigorous
and systematic land resettlement and redistribution program.
Same; Agricultural Leasehold; The agricultural leasehold subsists,
notwithstanding the resulting change in ownership of the landholding, and
the lessee’s rights are made enforceable against the

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* SECOND DIVISION.

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Estrella vs. Francisco

transferee or other successor-in-interest of the original lessor.—The


existence of an agricultural tenancy relationship between the lessor and the
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lessee gives the latter rights that attach to the landholding, regardless of
whoever may subsequently become its owner. This strengthens the security
of tenure of the tenants and protects them from being dispossessed of the
landholding or ejected from their leasehold by the death of either the lessor
or of the tenant, the expiration of a term/period in the leasehold contract, or
the alienation of the landholding by the lessor. If either party dies, the
leasehold continues to bind the lessor (or his heirs) in favor of the tenant (or
his surviving spouse/descendants). In case the lessor alienates the land, the
transferee is subrogated to the rights and substituted to the obligations of the
lessor-transferor. The agricultural leasehold subsists, notwithstanding the
resulting change in ownership of the landholding, and the lessee’s rights are
made enforceable against the transferee or other successor-in-interest of the
original lessor.
Same; Same; Right of Preemption; To protect the lessee’s security of
tenure, the Agricultural Land Reform Code grants him the right of
preemption — the preferential right to buy the landholding under
reasonable terms and conditions if ever the agricultural lessor decides to
sell it.—To protect the lessee’s security of tenure, the Code grants him the
right of preemption — the preferential right to buy the landholding under
reasonable terms and conditions if ever the agricultural lessor decides to sell
it. As an added layer of protection, the Code also grants him the right to
redeem the landholding from the vendee in the event that the lessor sells it
without the lessee’s knowledge.
Same; Same; Right of Redemption; In Mallari v. Court of Appeals, 161
SCRA 503 (1988), the Supreme Court (SC) held that the lessee’s right of
redemption will not prescribe if he is not served written notice of the sale.—
In Mallari v. Court of Appeals, 161 SCRA 503 (1988), we held that the
lessee’s right of redemption will not prescribe if he is not served written
notice of the sale. We affirmed this ruling in Springsun Management
Systems Corporation v. Camerino, 449 SCRA 65 (2005), and Planters
Development Bank v. Garcia, 477 SCRA 185 (2005). More recently in Po v.
Dampal, 608 SCRA 627 (2009), we held that the failure of the vendee to
serve written notice of the sale to the lessee and the DAR prevents the
running of the 180-day redemption period; the lessee’s constructive
knowledge of

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Estrella vs. Francisco

the sale does not dispense with the vendee’s duty to give written notice.
Simply put, Section 12 expressly states that the 180-day period must be
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reckoned from written notice of sale. If the agricultural lessee was never
notified in writing of the sale of the landholding, there is yet no prescription
period to speak of.
Same; Same; Same; After the amendment of Section 12 of the
Agricultural Land Reform Code, a certification from the Land Bank that it
will finance the redemption will also suffice in lieu of tender of payment or
consignation.—After the amendment of Section 12 of the Code, a
certification from the Land Bank that it will finance the redemption will also
suffice in lieu of tender of payment or consignation.
Same; Same; Same; Ordinarily, the one hundred eighty (180)-day
redemption period begins to run from the date that the vendee furnishes
written notice of the sale to the lessee. The filing of a petition or request for
redemption with the Department of Agrarian Reform (DAR) (through the
Provincial Agrarian Reform Adjudicator [PARAD]) suspends the running of
the redemption period.—In the present case, Estrella manifested his
willingness to pay the redemption price but failed to tender payment or
consign it with the PARAD when he filed his complaint. To be sure, a
tenant’s failure to tender payment or consign it in court upon filing the
redemption suit is not necessarily fatal; he can still cure the defect and
complete his act of redemption by consigning his payment with the court
within the remaining prescriptive period. Ordinarily, the 180-day
redemption period begins to run from the date that the vendee furnishes
written notice of the sale to the lessee. The filing of a petition or request for
redemption with the DAR (through the PARAD) suspends the running of
the redemption period.
Same; Same; Social Justice; While we endeavor to protect the rights of
agricultural lessees, we must be mindful not to do so at the expense of
trampling upon the landowners’ rights which are likewise protected by law.
—The Agricultural Land Reform Code is a social legislation designed to
promote economic and social stability. It must be interpreted liberally to
give full force and effect to its clear intent, which is “to achieve a dignified
existence for the small farmers” and to make them “more independent, self-
reliant and responsible citizens, and a source of genuine strength in our
democratic society.”

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Estrella vs. Francisco

Nevertheless, while we endeavor to protect the rights of agricultural


lessees, we must be mindful not to do so at the expense of trampling upon
the landowners’ rights which are likewise protected by law.

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PETITION for review on certiorari of a resolution of the Court of


Appeals.
The facts are stated in the opinion of the Court.
Valeriano B. Mariano for petitioner.

BRION, J.:

This petition for review on certiorari seeks to reverse and set


aside the November 28, 2012 resolution1 of the Court of Appeals
(CA) in C.A.-G.R. S.P. No. 121519.2 The CA dismissed petitioner
Urbano F. Estrella’s (Estrella) appeal from the Department of
Agrarian Reform Adjudication Board’s (DARAB) February 23,
2009 decision3 in DARAB Case No. 13185 which denied Estrella’s
right of redemption over an agricultural landholding.

Antecedents

Lope Cristobal (Cristobal) was the owner of a twenty-three


thousand nine hundred and thirty-three-square-meter (23,933 sq. m.)
parcel of agricultural riceland (subject landholding) in Cacarong
Matanda, Pandi, Bulacan, covered by Transfer Certificate of Title
(TCT) No. T-248106 of the Register of Deeds of Bulacan. Estrella
was the registered agricultural tenant-lessee of the subject
landholding.

_______________

1 Rollo, p. 30.
2 Penned by Associate Justice Normandie B. Pizarro and concurred in by
Associate Justices Remedios A. Salazar-Fernando and Leoncia R. Dimagiba.
3 Rollo, p. 91.

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Estrella vs. Francisco

On September 22, 1997, Cristobal sold the subject landholding to


respondent Priscilla Francisco (Francisco) for five hundred
thousand pesos (P500,000.00),4 without notifying Estrella.
Upon discovering the sale, Estrella sent Cristobal a demand letter
dated March 31, 1998, for the return of the subject landholding.5 He
also sent Francisco a similar demand letter dated July 31, 1998.
Neither Cristobal nor Francisco responded to Estrella’s demands.6

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On February 12, 2001, Estrella filed a complaint7 against


Cristobal and Francisco for legal redemption, recovery, and
maintenance of peaceful possession before the Office of the
Provincial Agrarian Reform Adjudicator (PARAD). His complaint
was docketed as DCN. R-03-02-2930’01.
Estrella alleged that the sale between Cristobal and Francisco
was made secretly and in bad faith, in violation of Republic Act
(R.A.) No. 3844, the Agricultural Land Reform Code (the Code).8
He insisted that he never waived his rights as a registered tenant
over the property and that he was willing to match the sale price.
Estrella concluded that as the registered tenant, he is entitled to
legally redeem the property from Francisco. He also manifested his
ability and willingness to deposit the amount of P500,000.00 with
the PARAD as the redemption price.9
Cristobal did not file an answer while Francisco denied all the
allegations in the complaint except for the fact of the sale.10
Francisco claimed that she was an innocent purchaser in good faith
because she only bought the property after: (1)

_______________

4 Id., at pp. 45 and 69.


5 Id., at p. 79.
6 Id., at p. 80.
7 Id., at p. 43.
8 The Agricultural Land Reform Code, R.A. No. 3844 (1963).
9 Rollo, p. 45.
10 Id., at p. 69.

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Estrella vs. Francisco

Cristobal assured her that there would be no problems regarding


the transfer of the property; and (2) Cristobal personally undertook
to compensate Estrella. Therefore, Estrella had no cause of action
against her.
On June 23, 2002, the PARAD rendered its decision recognizing
Estrella’s right of redemption.11 The PARAD found that neither
Cristobal nor Francisco notified Estrella in writing of the sale. In the
absence of such notice, an agricultural lessee has a right to redeem
the landholding from the buyer pursuant to Section 12 of the Code.12
Francisco appealed the PARAD’s decision to the DARAB where
it was docketed as DARAB Case No. 13185.

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On February 23, 2009, the DARAB reversed the PARAD’s


decision and denied Estrella the right of redemption.13 Citing
Section 12 of the Code as amended, the DARAB held that the right
of redemption may be exercised within 180 days from written notice
of the sale. Considering that more than three years had lapsed
between Estrella’s discovery of the sale and his filing of the case for
redemption, the DARAB concluded that Estrella slept on his rights
and lost the right to redeem the landholding.
Estrella moved for reconsideration but the DARAB denied the
motion.
On September 30, 2011, Estrella filed a motion before the CA to
declare himself as a pauper litigant and manifested his intention to
file a petition for review of the DARAB’s decision.14 He alleged that
he was living below the poverty line and did not have sufficient
money or property for food, shelter, and other basic necessities.

_______________

11 Id., at p. 84.
12 Id., at p. 88.
13 Id., at p. 91.
14 Id., at p. 9.

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Estrella vs. Francisco

On October 17, 2011, Estrella filed a petition for review15 of the


DARAB’s decision before the CA. The petition was docketed as
C.A.-G.R. S.P. No. 121519.
Estrella emphasized that the purpose of the State in enacting the
agrarian reform laws is to protect the welfare of landless farmers and
to promote social justice towards establishing ownership over the
agricultural land by the tenant-lessees.16 He insisted that the
DARAB erred in denying him the right of redemption based on a
technicality and that the redemption period in Sec. 12 of the Code
does not apply in his case because neither the lessor nor the vendee
notified him in writing of the sale.17
On November 28, 2012, the CA dismissed Estrella’s petition for
review for failure to show any reversible error in the DARAB’s
decision.18 Estrella received a copy of the CA’s resolution on April
10, 2013.19
On April 11, 2013, Estrella filed a motion for a twenty-day
extension of time (or until April 31, 2013) to file his motion for

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reconsideration of the November 28, 2012 resolution.20


On April 30, 2013, Estrella requested another ten-day extension
of time (or until May 9, 2013) to file his motion for
reconsideration.21
On May 9, 2013, Estrella filed his Motion for Reconsideration
arguing that his right of redemption had not yet prescribed because
he was not given written notice of the sale to Francisco.22

_______________

15 Id., at p. 51.
16 Id., at p. 61.
17 Id., at pp. 62 and 64.
18 Id., at p. 30.
19 Id., at p. 20.
20 Id., at pp. 20 and 36.
21 Id., at pp. 20 and 38.
22 Id., at pp. 20 and 40.

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Estrella vs. Francisco

On May 30, 2013, the CA denied Estrella’s motions for extension


of time, citing the rule that the reglementary period to file a motion
for reconsideration is non-extendible.23 The CA likewise denied
Estrelia’s Motion for Reconsideration.
Hence, the present recourse to this Court.
On August 23, 2013, Estrella filed a motion for extension of time
to file his petition for review and a motion to be declared as a pauper
litigant.24 We granted both motions on October 13, 2013.

The Parties’ Arguments

Estrella argues that an agricultural tenant’s right of redemption


over the landholding cannot prescribe when neither the lessor-seller
nor the buyer has given him written notice of the sale.
On the other hand, Francisco counters that Estrella failed to make
a formal tender of or to consign with the PARAD the redemption
price as required in Quiño v. Court of Appeals.25 She also questioned
the genuineness of Estrella’s claim to be a pauper litigant. Francisco
points out that a person who claims to be willing to pay the
redemption price of P500,000.00 is not, by any stretch of the
imagination, a pauper.26

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Our Ruling

We find no merit in the petition.


The use and ownership of property bears a social function, and
all economic agents are expected to contribute to the common
good.27 To this end, property ownership and economic

_______________

23 Id., at pp. 6 and 33.


24 Id., at p. 2.
25 353 Phil. 449; 291 SCRA 249 (1998).
26 Rollo, pp. 100-103.
27 Art. XII, Sec. 6, Constitution.

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Estrella vs. Francisco

activity are always subject to the duty of the State to promote


distributive justice and intervene when the common good requires.28
As early as 1973, the Philippines has already declared our goal of
emancipating agricultural tenants from the bondage of the soil.29
The State adopts a policy of promoting social justice, establishing
owner cultivatorship of economic-size farms as the basis of
Philippine agriculture, and providing a vigorous and systematic land
resettlement and redistribution program.30
In pursuit of land reform, the State enacted the Agricultural Land
Reform Code in 1963. The Code established an agricultural
leasehold system that replaced all existing agricultural share tenancy
systems at that point.
The existence of an agricultural tenancy relationship between the
lessor and the lessee gives the latter rights that attach to the
landholding, regardless of whoever may subsequently become its
owner.31 This strengthens the security of tenure of the tenants and
protects them from being dispossessed of the landholding or ejected
from their leasehold by the death of either the lessor or of the tenant,
the expiration of a term/period in the leasehold contract, or the
alienation of the landholding by the lessor.32 If either party dies, the
leasehold continues to bind the lessor (or his heirs) in favor of the
tenant (or his surviving spouse/descendants). In case the lessor
alienates the land, the transferee is subrogated to the rights and
substituted to the obligations of the lessor-transferor. The

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_______________

28 Id.
29 Art. XIV, Sec. 12, 1973 Constitution.
30 Sec. 2, Comprehensive Agrarian Reform Law of 1988, R.A. No. 6657 (1988);
Sec. 2, R.A. No. 6389 (1971).
31 Secs. 9 and 10, Agricultural Land Reform Code. See also Relucio III v.
Macaraig, Jr., 255 Phil. 613, 622; 173 SCRA 635, 643 (1989); and Planters
Development Bank v. Garcia, 513 Phil. 294, 307; 477 SCRA 185, 196 (2005).
32 Secs. 9 and 10, Agricultural Land Reform Code.

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Estrella vs. Francisco

agricultural leasehold subsists, notwithstanding the resulting


change in ownership of the landholding, and the lessee’s rights are
made enforceable against the transferee or other successor-in-
interest of the original lessor.
To protect the lessee’s security of tenure, the Code grants him the
right of preemption — the preferential right to buy the landholding
under reasonable terms and conditions if ever the agricultural lessor
decides to sell it.33 As an added layer of protection, the Code also
grants him the right to redeem the landholding from the vendee in
the event that the lessor sells it without the lessee’s knowledge.34
Originally, the lessee had a redemption period of two years from
registration of the sale:

Sec. 12. Lessee’s Right of Redemption.—In case the


landholding is sold to a third person without the knowledge of
the agricultural lessee, the latter shall have the right to redeem
the same at a reasonable price and consideration: Provided,
That the entire landholding sold must be redeemed: Provided,
further, That where there are two or more agricultural lessees,
each shall be entitled to said right of redemption only to the
extent of the area actually cultivated by him. The right of
redemption under this Section may be exercised within two
years from the registration of the sale, and shall have priority
over any other right of legal redemption.35

In Padasas v. Court of Appeals,36 we held that a lessee’s actual


knowledge of the sale of the landholding is immaterial because the
Code specifically and definitively provides that the redemption
period must be counted from the registration

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_______________

33 Sec. 11, Agricultural Land Reform Code, as amended.


34 Id., Sec. 12.
35 Sec. 12, Agricultural Land Reform Code (1963).
36 172 Phil. 243, 251-252; 82 SCRA 250, 259 (1978).

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Estrella vs. Francisco

of the sale. This ruling was subsequently affirmed in Manuel v.


Court of Appeals.37
In 1971, R.A. No. 6389 amended Section 12 of the Code and
shortened the redemption period:

Sec. 12. Lessee’s right of Redemption.—In case the


landholding is sold to a third person without the knowledge of
the agricultural lessee, the latter shall have the right to redeem
the same at a reasonable price and consideration: Provided,
That where there are two or more agricultural lessees, each
shall be entitled to said right of redemption only to the extent
of the area actually cultivated by him. The right of redemption
under this Section may be exercised within one hundred
eighty days from notice in writing which shall be served by
the vendee on all lessees affected and the Department of
Agrarian Reform upon the registration of the sale, and
shall have priority over any other right of legal redemption.
The redemption price shall be the reasonable price of the land
at the time of the sale.
Upon the filing of the corresponding petition or request
with the department or corresponding case in court by the
agricultural lessee or lessees, the period of one hundred and
eighty days shall cease to run.
Any petition or request for redemption shall be resolved
within sixty days from the filing thereof; otherwise, the said
period shall start to run again.
The Department of Agrarian Reform shall initiate, while
the Land Bank shall finance, said redemption as in the case of
preemption.38 [Emphases and underscoring supplied]

In Mallari v. Court of Appeals,39 we held that the lessee’s right of


redemption will not prescribe if he is not served writ-

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_______________

37 204 Phil. 109, 116; 118 SCRA 477, 483 (1982).


38 Sec. 12, Agricultural Land Reform Code, as amended by Sec. 4, R.A. No.
6389 (1971).
39 244 Phil. 518, 523; 161 SCRA 503, 507-508 (1988).

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Estrella vs. Francisco

ten notice of the sale. We affirmed this ruling in Springsun


Management Systems Corporation v. Camerino40 and Planters
Development Bank v. Garcia.41
More recently in Po v. Dampal,42 we held that the failure of the
vendee to serve written notice of the sale to the lessee and the DAR
prevents the running of the 180-day redemption period; the lessee’s
constructive knowledge of the sale does not dispense with the
vendee’s duty to give written notice.
Simply put, Section 12 expressly states that the 180-day period
must be reckoned from written notice of sale. If the agricultural
lessee was never notified in writing of the sale of the landholding,
there is yet no prescription period to speak of.43
As the vendee, respondent Francisco had the express duty to
serve written notice on Estrella, the agricultural lessee, and on the
DAR. Her failure to discharge this legal duty prevented the
commencement of the 180-day redemption period. Francisco only
gave written notice of the sale in her answer44 before the PARAD
wherein she admitted the fact of the sale.45 Thus, Estrella timely
exercised his right of redemption. To hold otherwise would allow
Francisco to profit from her own neglect to perform a legally
mandated duty.

_______________

40 Springsun Management Systems Corporation v. Camerino, 489 Phil. 769, 790;


449 SCRA 65, 86 (2005).
41 Planters Development Bank v. Garcia, supra note 31 at pp. 313-314; p. 203.
42 623 Phil. 523, 530; 608 SCRA 627, 635 (2009).
43 Springsun Management Systems Corp. v. Camerino, supra; and Planters
Development Bank v. Garcia, supra note 31 at pp. 313-314; pp. 201-202.
44 Rollo, p. 69.
45 See Planters Development Bank v. Garcia, supra note 31 at pp. 314-315; p.
203, citing Quiño v. Court of Appeals, supra note 25 at p. 457; p. 255, where we
considered summons and the accompanying petition as written notice of the sale.
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Estrella vs. Francisco

However, despite the timely filing of the redemption suit, Estrella


did not validly exercise his right to redeem the property. As early as
1969 in Basbas v. Entena,46 this Court had already held that the valid
exercise of the right of redemption requires either tender of the
purchase price or valid consignation thereof in Court:

x x x the right of legal redemption must be exercised


within specified time limits; and the statutory periods would
be rendered meaningless and of easy evasion unless the
redemptioner is required to make an actual tender in good
faith of what he believed to be the reasonable price of the land
sought to be redeemed. The existence of the right of
redemption operates to depress the market value of the land
until the period expires, and to render that period indefinite by
permitting the tenant to file a suit for redemption, with either
party unable to foresee when final judgment will terminate the
action, would render nugatory the period of two years [now
180 days] fixed by the statute for making the redemption and
virtually paralyze any efforts of the landowner to realize the
value of his land. No buyer can be expected to acquire it
without any certainty as to the amount for which it may be
redeemed, so that he can recover at least his investment in
case of redemption. In the meantime, the landowner’s needs
and obligations cannot be met. It is doubtful if any such result
was intended by the statute, absent clear wording to that
effect.
The situation becomes worse when, as shown by the
evidence in this case, the redemptioner has no funds and must
apply for them to the Land Authority, which, in turn, must
depend on the availability of funds from the Land Bank. It
then becomes practically certain that the landowner will not
be able to realize the value of his property for an indefinite
time beyond the two years redemption period.47

_______________

46 138 Phil. 721; 28 SCRA 665 (1969).


47 Id., at p. 728; pp. 671-672.

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After the amendment of Section 12 of the Code, a certification


from the Land Bank that it will finance the redemption will also
suffice in lieu of tender of payment or consignation.48
In the present case, Estrella manifested his willingness to pay the
redemption price but failed to tender payment or consign it with the
PARAD when he filed his complaint. To be sure, a tenant’s failure to
tender payment or consign it in court upon filing the redemption suit
is not necessarily fatal; he can still cure the defect and complete his
act of redemption by consigning his payment with the court within
the remaining prescriptive period.49
Ordinarily, the 180-day redemption period begins to run from the
date that the vendee furnishes written notice of the sale to the lessee.
The filing of a petition or request for redemption with the DAR
(through the PARAD) suspends the running of the redemption
period.
However, as the cases of Basbas and Almeda v. Court of
Appeals50 — as well the amendment to Section 12 of the Code —
evidently show, Congress did not intend the redemption period to be
indefinite. This 180-day period resumes running if the petition is not
resolved within sixty days.51
Because Francisco failed to serve Estrella written notice of the
sale, Estrella’s 180-day redemption period was intact when he filed
the complaint before the PARAD. The filing of the complaint
prevented the running of the prescription period and gave Estrella
time to cure the defect of his redemption through consignment of the
redemption price.
After the lapse of sixty days, Estrella’s 180-day redemption
period began running pursuant to Section 12 of the Code.

_______________

48 Mallari v. Court of Appeals, supra note 39 at p. 524; p. 509.


49 Lusung v. Vda. de Santos, 204 Phil. 302, 309; 118 SCRA 669, 676 (1982).
50 168 Phil. 348, 355; 78 SCRA 194, 200 (1977).
51 Sec. 12, Agricultural Land Reform Code, as amended.

604

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Estrella vs. Francisco

Nevertheless, Estrella could still have consigned payment within


this 180-day period.
The exercise of the right of redemption must be made in
accordance with the law. Tender of the redemption price or its valid
consignation must be made within the prescribed redemption
period.52 The reason for this rule is simple:

x x x Only by such means can the buyer become certain


that the offer to redeem is one made seriously and in good
faith. A buyer cannot be expected to entertain an offer of
redemption without attendant evidence that the
redemptioner can, and is willing to accomplish the
repurchase immediately. A different rule would leave the
buyer open to harassment by speculators or crackpots as
well as to unnecessary prolongation of the redemption
period, contrary to the policy of the law. While
consignation of the tendered price is not always necessary
because legal redemption is not made to discharge a
preexisting debt, a valid tender is indispensable, for the
reasons already stated. Of course, consignation of the price
would remove all controversy as to the redemptioner’s ability
to pay at the proper time.53 [Emphasis supplied]

Unfortunately, even after the lapse of the 240 days (the 60-day
freeze period and the 180-day redemption period), there was neither
tender nor judicial consignation of the redemption price. Even
though Estrella repeatedly manifested his willingness to consign the
redemption price, he never actually did.

_______________

52 Almeda v. Court of Appeals, supra note 50 at pp. 355-356; pp. 199-200;


Baltazar v. Court of Appeals, 192 Phil. 137, 154; 104 SCRA 619, 633 (1981);
and Lusung v. Vda. de Santos, supra note 49 at pp. 307, 309; p. 676.
53 Conejero v. Court of Appeals, No. L-21812, April 29, 1966, 16 SCRA 775,
781-782, cited in Basbas v. Entena, supra note 46 at p. 727; p. 200 and in Almeda v.
Court of Appeals, supra note 50 at p. 356; p. 670.

605

VOL. 794, JUNE 27, 2016 605


Estrella vs. Francisco
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While Estrella exercised his right of redemption in a timely


manner, the redemption was ineffective because he failed to exercise
this right in accordance with the law. Notably, he had also repeatedly
manifested his inability to even pay judicial costs and docket fees.
He has been declared (twice) as a pauper litigant who was “living
below the poverty threshold level because of limited income.”54 This
casts considerable doubt on Estrella’s ability to pay the full price of
the property. In sum, we have no choice but to deny the petition.
The Agricultural Land Reform Code is a social legislation
designed to promote economic and social stability. It must be
interpreted liberally to give full force and effect to its clear intent,
which is “to achieve a dignified existence for the small farmers” and
to make them “more independent, self-reliant and responsible
citizens, and a source of genuine strength in our democratic
society.”55 Nevertheless, while we endeavor to protect the rights of
agricultural lessees, we must be mindful not to do so at the expense
of trampling upon the landowners’ rights which are likewise
protected by law.
WHEREFORE, we hereby DENY the petition for lack of merit;
accordingly, we AFFIRM the November 28, 2012 resolution of the
Court of Appeals in C.A.-G.R. S.P. No. 121519. No costs.
SO ORDERED.

Carpio (Chairperson), Mendoza and Leonen, JJ., concur.


Del Castillo, J., On Leave.

Petition denied, resolution affirmed.

_______________

54 Rollo, p. 34.
55 Catorce v. Court of Appeals, 214 Phil. 181, 184-185; 129 SCRA 210, 215
(1984).

606

606 SUPREME COURT REPORTS ANNOTATED


Estrella vs. Francisco

Notes.—Under Section 8 of R.A. No. 3844, the agricultural


leasehold relation shall be abandoned only under any of the
following three circumstances, to wit: “(1) abandonment of the
landholding without the knowledge of the agricultural lessor; (2)
voluntary surrender of the landholding by the agricultural lessee,
written notice of which shall be served three months in advance; or
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(3) absence of the persons under Section 9 to succeed the lessee.”


(Coderias vs. Estate of Juan Chioco, 699 SCRA 684 [2013])
Under Section 7 of R.A. No. 3844, once the leasehold relation is
established, the agricultural lessee is entitled to security of tenure
and acquires the right to continue working on the landholding.
(Davao New Town Development Corporation vs. Saliga, 712 SCRA
260 [2013])

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