Palo-Palo v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioner Vicente Palo-Palo filed a complaint seeking to exercise his right of redemption or pre-emption as a tenant under Republic Act No. 3844, as amended by Republic Act No. 6389, over a landholding. Petitioner alleged he began his tenancy in 1949, and the property was subsequently sold to spouses Justin and Zosima Taño, who recognized his tenancy. The Taños then sold the property in October 1978 to private respondents Abraham Palalon and Agripina Gadiane. Private respondents initially allowed petitioner to cultivate the land but later dispossessed him by plowing and planting corn. Procedural History: The Regional Trial Court (RTC) ruled in favor of the defendants (private respondents), holding that petitioner could not avail himself of the right of pre-emption because he was not a tenant. The RTC's decision was based on the Deed of Absolute Sale presented by both parties, which stated the property was "not tenanted," and the court concluded petitioner was bound by this statement. The Intermediate Appellate Court (IAC) affirmed the RTC's decision, reiterating that petitioner, by introducing the deed of sale as his Exhibit "B", was conclusively bound by its contents, including the statement that the property was not tenanted. The Petition: Petitioner filed a petition for review on certiorari, arguing that he introduced the deed of sale solely to prove the fact of conveyance and the consideration, not to be bound by its statement that the property was not tenanted, as he was neither a party nor a signatory to the deed. He contended that the identity of the landholding and his tenancy were established matters.
Issue(s)
Whether petitioner is bound by the statement in the deed of sale that the property is not tenanted. Whether the landholding claimed by petitioner as a tenant is the same property sold by the spouses Taño to Abraham and Agripina. Whether petitioner is indeed a tenant of the landholding.
Ruling
The decision of the Intermediate Appellate Court is set aside, and a new one is granted recognizing the right of pre-emption or redemption of petitioner over the subject property in accordance with Republic Act No. 3844, as amended by Republic Act No. 6389.
Ratio Decidendi
On the issue of whether petitioner is bound by the statement in the deed of sale that the property is not tenanted: The Supreme Court held that petitioner is not bound by the statement in the deed of sale that the property is not tenanted. While petitioner introduced the deed of sale, it was solely for the purpose of proving the fact of conveyance of the landholding, which is an essential requisite for claiming the right of pre-emption or redemption. The Court emphasized that petitioner cannot be bound by statements in a document to which he was not a party nor a signatory. The ruling in People vs. Cuaresma and other cited cases, which states that any party introducing a document is conclusively bound thereby, was distinguished as not applicable in this context where the purpose of introduction was limited and the party was not a signatory. On the issue of the identity of the landholding: The Supreme Court found that the identity of the landholding claimed by petitioner and the property sold by the spouses Taño to Abraham and Agripina was a settled matter. This was established by the report of CAR Deputy Sheriff Montano A. Galvez, Sr., who stated that "It is further agreed by both parties present that the land inspected by the undersigned is the same land in question." The trial court also noted that there was no question as to the identity of the land, as evidenced by the joint identification by the plaintiff and the statement of the defendants' counsel. On the issue of whether petitioner is a tenant of the landholding: The Supreme Court determined that the fact of petitioner's tenancy was also established. This was based on the amended answer of the private respondents, wherein they admitted "that the plaintiff had been a tenant of the late Zacarias Palacain in the land of the latter." This admission, coupled with the established identity of the land, confirmed petitioner's status as a tenant over the landholding in question. The Court concluded that both the trial court and the appellate court could have found for the petitioner had they not been unduly swayed by the statement in the deed of sale.
Main Doctrine
A party is not bound by statements in a deed of sale to which they are not a signatory, especially when the purpose of introducing the deed is solely to prove the fact of conveyance.