Lusung v. Vda. de Santos
REITERATIONFacts
The Antecedents: Respondent Susana Vda. de Santos, an agricultural lessee, sought to compel petitioners Lucia Lusung and Leoncia Z. Pineda to allow her to redeem a 3-hectare agricultural landholding. The land was originally owned by petitioner Leoncia Z. Pineda and subsequently sold to petitioner Lucia Lusung. Respondent alleged that the sale was made without the notice required under Sections 11 and 12 of Republic Act No. 3844 (Agricultural Land Reform Code), and prayed for the cancellation of the deed of sale. Procedural History: The Court of Agrarian Relations dismissed the complaint, holding that the respondent failed to state a cause of action for failure to allege a valid payment, tender of payment, or consignation of the purchase price within the period fixed by law. On appeal, the Court of Appeals reversed the dismissal, finding that respondent had complied with the requirements of Section 12 of R.A. 3844 by making a valid tender of payment within the prescribed period. The appellate court remanded the case for determination of the redemption price. Petitioners' motion for reconsideration was denied. The Petition: Petitioners seek to set aside the decision of the Court of Appeals and reinstate the order of dismissal of the Court of Agrarian Relations.
Issue(s)
Whether the Court of Appeals erred in holding that respondent complied with the requirements of Section 12 of Republic Act No. 3844 in exercising her right of redemption. Whether a prior valid tender of payment or consignation of the purchase price is indispensable for the exercise of the right of redemption by an agricultural lessee under Section 12 of Republic Act No. 3844. Whether the notice of sale given by the landowner to the agricultural lessee was legally sufficient.
Ruling
The appealed judgment of the Court of Appeals is affirmed. The dismissal order of the Court of Agrarian Relations is set aside.
Ratio Decidendi
On the compliance with Section 12 of R.A. 3844: The Court held that the Court of Appeals correctly ruled that respondent complied with the requirements of Section 12 of Republic Act No. 3844. The provision explicitly states that the right of redemption may be exercised within two years from the registration of the sale. The deed of sale was registered on July 30, 1968, and the deposit of P2,500.00 in cash and a P22,500.00 Land Bank bond was made well within the two-year period. The Court emphasized that this specific provision for agricultural lessees constitutes an exception to the general rules on legal redemption under the Civil Code, granting a longer period for exercise. On the necessity of prior tender of payment or consignation: The Court reiterated that the lower court erred in dismissing the action on the ground of no previous tender of payment. The law, specifically Section 12 of Republic Act No. 3844, does not require a previous tender of payment before the right of redemption can be exercised. The appellate court correctly ruled that the consignation made after the filing of the complaint is not fatal, as long as it completes the act of redemption within the two-year period from the registration of the sale. This aligns with established jurisprudence that such consignation within the statutory period is sufficient. On the sufficiency of the notice of sale: The Court noted that the claim of petitioners regarding written notice sent to the respondent could not be raised for the first time on appeal, as evidence should have been adduced before the lower court. Even if considered, the notice appears legally insufficient because it did not state the principal terms and conditions of the sale, which are necessary for the agricultural lessee to properly exercise their right of pre-emption and/or redemption. The law aims to encourage owner-cultivatorship by giving agricultural lessees priority and a longer period to redeem.
Main Doctrine
The right of redemption of an agricultural lessee under Section 12 of Republic Act No. 3844 may be exercised within two years from the registration of the sale, and consignation of the purchase price within this period, even after the filing of the complaint, constitutes a valid exercise of said right.