Springsun Management Systems Corp. v. Camerino
REITERATIONFacts
The Antecedents: Victoria Homes, Inc. (Victoria Homes) owned three adjoining lots. Respondents, Oscar Camerino, Efren Camerino, Cornelio Mantile, Nolasco del Rosario, and Domingo Enriquez, had been farmers-tenants cultivating these lots since 1967. Victoria Homes sold two lots to petitioner Springsun Management Systems Corporation (Springsun) on February 9, 1983, and the third lot on July 12, 1983, without notifying the respondents. Springsun subsequently mortgaged the lots to Banco Filipino Savings and Mortgage Bank (Banco Filipino) for loans. Upon Springsun's failure to pay, the mortgage was foreclosed, and the lots were sold to Banco Filipino at auction. Procedural History: Springsun filed forcible entry cases against the farm helpers of respondents in the Metropolitan Trial Court (MeTC). The MeTC dismissed these cases for lack of cause of action. On appeal, the Regional Trial Court (RTC), Branch 276, reversed the MeTC, finding the lots to be "unimproved residential" and ordering the respondents and their farm helpers to vacate. The sheriff turned over possession to Springsun. Meanwhile, respondents filed a complaint for redemption, prohibition, certiorari, reconveyance, damages, and injunction with preliminary injunction against Springsun and Banco Filipino in the RTC, Branch 256. The RTC authorized respondents to redeem the lots from Springsun. Springsun appealed to the Court of Appeals (CA), which affirmed the RTC decision with modification (deleting attorney's fees). Springsun then filed the instant petition for review on certiorari with the Supreme Court. The Petition: Springsun assails the CA's decision, arguing that the RTC lacked jurisdiction over agrarian reform matters, that respondents are not tenants, and that their right of redemption had prescribed.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction over the complaint for redemption involving agrarian reform matters. Whether the respondents are tenants or agricultural lessees of the disputed lots. Whether the respondents are entitled to exercise their right of redemption over the lots. Whether the respondents' right of redemption had prescribed.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals in CA-G.R. No. 72475 are AFFIRMED IN TOTO. Costs against petitioners.
Ratio Decidendi
On the jurisdiction of the RTC: The Supreme Court ruled that petitioner Springsun is estopped from assailing the jurisdiction of the RTC. Springsun actively participated in the proceedings before the RTC and the Court of Appeals without raising the issue of jurisdiction. It invoked the jurisdiction of the courts by filing forcible entry cases and by participating in the redemption case, including presenting its own witness. The Court emphasized that a party cannot invoke the jurisdiction of a court to secure affirmative relief and then repudiate that same jurisdiction after an adverse judgment. Furthermore, Section 12 of R.A. No. 3844 explicitly allows for a petition for redemption to be filed in court, not exclusively with the Department of Agrarian Reform (DAR). On whether respondents are tenants: The Supreme Court affirmed the findings of fact of the trial court and the Court of Appeals that the respondents are tenants or agricultural lessees. This is a factual issue that the Supreme Court, as a court of review, does not ordinarily pass upon. Both lower courts found that respondents had been cultivating the lands since 1967, planting rice, corn, and vegetables, and sharing the produce with the landowners' caretakers. The actual use of the land, not its classification by the local taxing authority, determines its agricultural nature. The RTC's finding in the forcible entry cases that the lots were "unimproved residential" was not conclusive for the redemption case, as the issue there was only physical possession. On the right of redemption: The Court held that respondents are entitled to redeem the lots. Under Section 12 of Republic Act No. 3844, as amended, agricultural lessees have the right to redeem landholdings sold to third persons without their knowledge. The sales from Victoria Homes to Springsun were made without notice to the respondents or the DAR. The Court reiterated that this right of redemption is statutory and attaches by operation of law. The RTC correctly determined the redemption price based on the acquisition costs from Victoria Homes. On prescription of the right of redemption: The Supreme Court ruled that the right of redemption had not prescribed. The defense of prescription must be raised in the trial court and cannot be raised for the first time on appeal. Moreover, the prescriptive period of 180 days under Section 12 of R.A. No. 3844 begins from notice in writing served by the vendee on all lessees affected and the DAR. Since respondents were never notified in writing of the sale, the prescriptive period did not commence, and thus, there was no prescription to speak of.
Main Doctrine
Agricultural lessees have a statutory right of redemption when the landholding is sold to a third person without their knowledge, and this right is not lost due to procedural technicalities or belated challenges to jurisdiction, especially when the party challenging has actively participated in the proceedings.