Gonzales v. Intermediate Appellate Court and Melchor Matic
REITERATIONFacts
The Antecedents: Petitioner Leticia Gonzales was the owner of two parcels of riceland. She executed a tenancy agreement with private respondent Melchor Matic, making him the tenant. Subsequently, petitioner sold one parcel to Rodolfo Tagle and the other to Isabelita Aldea without the knowledge of and without offering them for sale to private respondent, in violation of Section 12 of RA 6389. Procedural History: Private respondent learned of the sales in November 1981 and offered to redeem the land, but petitioner refused. He filed a complaint for redemption before the Court of Agrarian Relations (CAR), later consigning the redemption money. The CAR dismissed the complaint, ruling that the sales were fictitious and simulated, intended to create a trust, and thus no right of redemption could arise. The Intermediate Appellate Court (IAC) set aside the CAR decision, ruling that the contracts were absolute sales and that petitioner could not later claim they were fictitious based on her own testimony. The IAC sustained private respondent's right to redeem. The Petition: Petitioner appealed the IAC decision to the Supreme Court, arguing against the private respondent's right of redemption.
Issue(s)
Whether the contracts of sale executed by the petitioner were fictitious or simulated, thereby negating the private respondent's right of redemption. Whether the private respondent, as an agricultural lessee, has the right to redeem the subject landholdings.
Ruling
The Supreme Court dismissed the petition and affirmed the decision of the Intermediate Appellate Court, upholding the private respondent's right to redeem the properties.
Ratio Decidendi
On the issue of fictitious or simulated sales and the right of redemption: The Court held that the petitioner's claim that the contracts were fictitious and simulated was untenable. The contracts were clearly worded as absolute sales, and the petitioner herself admitted that they were intended to transfer legal title to the vendees, Aldea and Tagle, while she retained beneficial ownership. Furthermore, she executed an affidavit of non-tenancy to facilitate the registration of the sales and the issuance of new certificates of title to the vendees. Having taken these actions, the petitioner could not subsequently claim that the contracts were fictitious or simulated to frustrate the right of redemption accorded to the agricultural lessee by law. The adequacy or inadequacy of the consideration, or even the absence of consideration, is a matter between the parties to the sale and cannot be invoked to defeat the tenant's statutory right of redemption. On the issue of the agricultural lessee's right to redeem: The Court reiterated that the right of redemption is granted under Section 12 of RA 6389 (Agricultural Land Reform Code) in cases where the landholding is sold to a third person without the knowledge of the agricultural lessee. The lessee has the right to redeem the same at a reasonable price and consideration within 180 days from notice of the sale, which right has priority over any other right of legal redemption. The petitioner's actions directly contravened this provision by selling the land without notice to the tenant and then attempting to use her own alleged fictitious intent to nullify the tenant's legal right.
Main Doctrine
A tenant's right of redemption under Section 12 of RA 6389 is not defeated by the landowner's claim that the sale was fictitious or simulated, especially when the landowner herself executed contracts of absolute sale, transferred legal title, and even executed an affidavit of non-tenancy.