Marcelo v. Gucilatar
REITERATIONFacts
The Antecedents: This case involves a dispute over agricultural landholdings. Respondent Juanito Gucilatar claims ownership of several parcels of land after a sheriff's sale due to a mortgage default by the former owner, Gerardo Domingo. Gucilatar filed an ejectment case against petitioners Josefina Marcelo, Eligio Capule, and Carlito Nicodemus, alleging they defied a writ of possession, failed to pay rentals for five harvest seasons, assigned their cultivation rights to third parties, and converted the land into a fishpond. The petitioners, however, asserted their status as recognized agricultural tenants with security of tenure, claiming they continued to pay rentals to Gerardo Domingo until January 2007, and that the mortgage and subsequent sale occurred without their knowledge. Procedural History: The dispute originated from two separate cases filed before the Office of the Provincial Agrarian Reform Office in Malolos City. In DARAB Case No. R-03-02-4768'07, Gucilatar filed an ejectment case, which the Provincial Adjudicator ruled in his favor on May 5, 2010, ordering the petitioners to vacate and pay damages. In DARAB Case No. R-03-02-5437'07, filed on November 22, 2007, the petitioners sought to exercise their right of redemption over the subject lands. The Provincial Adjudicator ruled in favor of the petitioners on August 24, 2011, upholding their right to redeem the landholdings. Both parties appealed these decisions. The Department of Agrarian Reform Adjudication Board (DARAB) consolidated the appeals and, in a decision dated July 5, 2013, affirmed the ejectment ruling while reversing the redemption ruling, finding that the petitioners failed to properly exercise their right of redemption. The Court of Appeals, in a decision dated October 23, 2015, affirmed the DARAB's consolidated decision. The Petition: Petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' decision. They argued that the CA erred in holding that their exercise of the right of redemption was ineffectual due to their failure to tender or consign the full redemption price. Petitioners contended that, citing Hulganza v. Court of Appeals and Anecita Gregorio v. Maria Crisologo Vda. de Culig, the filing of the redemption action itself is equivalent to a formal offer to redeem, and thus, the absence of a prior tender or consignation should not defeat their right. They also argued that they were not properly notified of the sale, which is a prerequisite for the redemption period to commence.
Issue(s)
Whether petitioners validly exercised their right of redemption. Whether the failure to tender or consign the redemption price renders the exercise of the right of redemption ineffectual.
Ruling
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision of the Court of Appeals, and rendered judgment UPHOLDING the right of redemption of the petitioners, REMANDED the case to the DARAB to determine the reasonable price for redemption, and DIRECTED the LBP to finance the redemption.
Ratio Decidendi
On the issue of whether petitioners validly exercised their right of redemption: The Court held that petitioners, as agricultural tenants, have a right of redemption under Section 12 of R.A. No. 3844, as amended by R.A. No. 6389, in case the landholding is sold to a third person without their knowledge. It was undisputed that petitioners were agricultural tenants and that they were not notified in writing of the sale of the properties. The Court emphasized that without such written notice, the 180-day prescriptive period for redemption does not begin to run. The petition for redemption was filed within the prescriptive period. The Court cited Spouses Franco v. Spouses Galera, Jr. to underscore the aim of agrarian justice to make tenants owners of the land they till. On the issue of whether the failure to tender or consign the redemption price renders the exercise of the right of redemption ineffectual: The Court clarified that while tender or consignation is generally an indispensable requirement for the proper exercise of the right of redemption, this must be read in conjunction with the mandate in Section 12 of R.A. No. 3844 for the Land Bank of the Philippines (LBP) to finance such redemptions. The Court reasoned that agricultural tenants may not always have ready cash, and to indiscriminately dismiss redemption cases due to failure to tender or consign the price would render the LBP financing provision nugatory. Therefore, in cases where the tenant files a redemption case without consigning or tendering the price, a certification from the LBP that it will finance the redemption should suffice. This interpretation aligns with the policy of agrarian justice and social justice, aiming to give land to those who cultivate it and liberate them from oppressive systems.
Main Doctrine
In cases involving the right of redemption of agricultural tenants under Section 12 of R.A. No. 3844, as amended, the filing of a redemption case, coupled with a certification from the Land Bank of the Philippines that it will finance the redemption, can suffice in lieu of a prior tender or consignation of the redemption price, to give effect to the agrarian justice policy.