De Jesus v. Caluag
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an agricultural parcel of land in Barrio Sta. Rita, Guiguinto, Bulacan, with an area of 1.874 hectares. The private respondents, Spouses Fernando Caluag and Lucena Hernandez, purchased the land and sought to eject the petitioner, Felix de Jesus, an agricultural lessee, alleging he refused to vacate after receiving written notice of the respondent's intent to personally cultivate the land. The petitioner admitted the purchase but counterclaimed, asserting he was not notified by the former owners of their intention to sell, thus depriving him of his right of pre-emption, and that he was exercising his right to redeem the land for the purchase price of P6,000.00. 2. Procedural History: The respondents initially filed a complaint for ejectment against the petitioner with the court of agrarian relations in Malolos, Bulacan. The agrarian court, on May 7, 1968, ordered the petitioner's ejectment and dismissed his counterclaim for redemption, despite finding him to be the agricultural lessee. The petitioner appealed this decision to the Court of Appeals, assigning the denial of his redemption counterclaim as the sole error. The Court of Appeals, in its decision of March 12, 1971, ruled that while the petitioner had deposited the redemption amount within the statutory period, his subsequent withdrawal of this deposit from the court, made ex-parte and without the respondent's knowledge, constituted a forfeiture of his right to redeem. 3. The Petition: The petitioner seeks review by certiorari of the Court of Appeals' decision, arguing that the appellate court erred in holding that his withdrawal of the redemption deposit, made while actively pursuing his appeal and asserting his right to redeem, resulted in the forfeiture of that right. The petitioner contends that the timely deposit constituted a valid tender of payment and that, as established in jurisprudence, withdrawing such a deposit during the pendency of the case does not affect the right of redemption, as redemption is optional. He argues that he was not obligated to keep the funds frozen while seeking judicial confirmation of his right to redeem, which was being contested by the respondents and denied by the lower courts.
Issue(s)
Whether the withdrawal of the redemption deposit by the petitioner-lessee during the pendency of his appeal affects his right to redeem the landholding. Whether the agrarian court's denial of the counterclaim for redemption was proper.
Ruling
The Supreme Court set aside and reversed the decision of the Court of Appeals. It authorized the petitioner's redemption of the landholding and ordered the private respondents to execute a deed of absolute conveyance in favor of the petitioner upon payment of P6,000.00 within sixty (60) days from the finality of the decision.
Ratio Decidendi
On the issue of withdrawal of redemption deposit: The Court held that the appellate court's conclusion that the petitioner "has changed his mind and decided not to repurchase the property" and thus "forfeited his right to redeem" by withdrawing the P6,000.00 deposit is untenable in law. The Court reiterated the well-established jurisprudence that the timely exercise of the right of legal redemption requires either a valid tender of the price or valid consignation thereof. The deposit of the redemption price in the agrarian court constituted a valid tender of payment. The withdrawal of the deposit during the pendency of the case does not affect the right of redemption, as such redemption is optional and not compulsory. This principle was established in Butte vs. Manuel Uy & Sons, Inc.. The withdrawal only affects the legal consequences, specifically the entitlement to the fruits and benefits of the property until the redemption price is actually paid to the purchaser. Therefore, the petitioner was under no obligation to keep his money frozen on deposit while pursuing his appeal for judicial confirmation of his right to redeem, which was being resisted by the respondents and denied by the lower court. The appellate court erred in deeming the withdrawal as an act of forfeiture of the right to redeem, especially when the petitioner was actively pursuing his appeal and insisting on his right. On the propriety of the agrarian court's denial of redemption: The Court found that the agrarian court, and subsequently the appellate court, erred in denying the petitioner's counterclaim for redemption. The appellate court itself found that the notice of sale by the former owners was legally insufficient for not stating the principal terms and conditions of the sale, which is a prerequisite for the agricultural lessee to properly exercise the right of pre-emption under Section 11 of Republic Act No. 3844. Furthermore, the appellate court acknowledged that the petitioner's deposit of P6,000.00 was made well within the two-year period for redemption under Section 12 of the same Act, and that the petitioner was ready and able to pay the amount. The appellate court's affirmation of the agrarian court's denial was based on the erroneous premise that the withdrawal of the deposit constituted a forfeiture of the right to redeem. Since the petitioner had validly exercised his right to redeem by depositing the redemption price within the statutory period and was pursuing his appeal to confirm this right, the denial of his counterclaim was improper.
Main Doctrine
The withdrawal of the redemption amount deposited in court during the pendency of an appeal does not affect the right of redemption, as such redemption is optional and not compulsory. The withdrawal merely impacts the consequences of the redemption, such as the entitlement to fruits and benefits, until the redemption price is actually paid.