Sucaldito v. Montejo
REITERATIONFacts
1. The Antecedents: Petitioners Crisostomo Sucaldito and Felisa de Guzman, who were grantees of two parcels of public agricultural land through free patent, sold these lots to respondents Blas and Paciencia Labad for P65,000.00 on March 14, 1972. Following the sale, the respondents took possession and cultivated the land. The petitioners subsequently expressed their desire to repurchase the lots and, upon receiving no satisfactory reply, filed an action for reconveyance. 2. Procedural History: The Regional Trial Court (RTC) of Davao del Sur initially ruled in favor of the petitioners, granting them the right to repurchase the land within thirty days of the decision becoming final, provided they paid P73,103.79. The respondents appealed to the Court of Appeals (CA), which reversed the RTC decision, dismissing the petitioners' complaint for lack of offer to repurchase. The CA later granted the petitioners' motion for reconsideration, reinstating the RTC's decision. This led to a petition for certiorari by the respondents to the Supreme Court (SC), which was dismissed. The RTC subsequently dismissed the petitioners' motion to deposit the repurchase price, ruling that the repurchase period had expired. The CA denied the petitioners' subsequent motions for reconsideration. 3. The Petition: This petition for review on certiorari seeks to annul the RTC resolutions that dismissed the petitioners' right to repurchase the lots. The petitioners argue that the RTC erred in applying a thirty-day repurchase period instead of the five-year period mandated by Section 119 of Commonwealth Act No. 141, and that they made a valid tender of payment within the legally prescribed period. The SC is asked to set aside the RTC's adverse resolutions and allow the petitioners to repurchase the lands.
Issue(s)
Whether the RTC committed a reversible error in ruling that the period for petitioners to exercise their right of redemption is the period specified in the trial court's decision and not the period provided in Sec. 119 of CA 141, as amended. Whether the RTC erred in not ruling that there was a valid tender of payment made by petitioners within the period provided for under Sec. 119 of CA 141, as amended.
Ruling
The Supreme Court GRANTED the petition. The RTC resolutions dated October 8, 1984, August 19, 1985, and May 14, 1986, were SET ASIDE. Respondents were directed to execute a deed of reconveyance in favor of petitioners within ten (10) days from the finality of the decision, simultaneously with their withdrawal of the deposited amount. If respondents failed to execute the deed, the Clerk of Court was directed to do so upon delivery of the deposited amount to the respondents.
Ratio Decidendi
On the issue of the applicable redemption period: The RTC erred in imposing a thirty-day period for repurchase, which was not provided for in Section 119 of Commonwealth Act No. 141. This section clearly grants a five-year period for repurchase from the date of conveyance for lands acquired under free patent. The Court reiterated that where the law speaks in clear and categorical language, there is no room for interpretation, only application. The RTC's imposition of a shorter period was an unlawful addition to the statutory right, constituting judicial legislation. The filing of the action for reconveyance on July 10, 1975, effectively suspended the running of the redemption period, keeping petitioners within the protective mantle of Section 119 of CA 141. The period commenced to run again only on March 26, 1983, when the Supreme Court's resolution became final. On the issue of valid tender of payment: The petitioners' filing of the action for reconveyance on July 10, 1975, was within the five-year period from the conveyance on March 14, 1972. This action tolled the redemption period. The Supreme Court's resolution in G.R. No. 61286 became final on March 26, 1983. Petitioners deposited the repurchase price of P73,103.79 with the RTC on November 9, 1984. The period from March 26, 1983, to November 9, 1984, is one year and 228 days. Cumulatively, the total period from the initial conveyance to the deposit was four years and 346 days, which is well within the five-year statutory period. Therefore, the deposit made on November 9, 1984, constituted a valid payment of the repurchase price within the period provided by law.
Main Doctrine
The filing of an action for reconveyance to enforce the right to repurchase land acquired under free patent within the five-year period granted by Section 119 of Commonwealth Act No. 141 suspends the running of the redemption period. The repurchase price must be paid within the five-year period from the date of conveyance, or within the extended period as determined by the court, considering the suspension caused by the legal action.