Sampilo v. Amistad
REITERATIONFacts
The Antecedents: The case involves a parcel of land (1.9860 hectares) formerly owned by Claudia Udyang Reble (Reble), which was under a leasehold tenancy agreement with petitioner Felix Sampilo. On June 14, 2004, Reble executed an Extra-Judicial Partition with Sale, selling the property to respondent Eliaquim Amistad. Petitioner received a Summons and Notice for a conference on May 29, 2008. During a conference on June 2, 2008, respondent informed petitioner of the purchase and presented the deed of sale. Petitioner was asked to vacate the property. Procedural History: On December 22, 2008, petitioner filed a Complaint for Redemption and Consignation against respondent. The Provincial Agrarian Reform Adjudicator (PARAD) dismissed the complaint, finding that while petitioner was a tenant entitled to redeem, the action was filed beyond the four-year prescriptive period from the execution of the deed of conveyance. The DARAB denied petitioner's appeal, ruling that petitioner failed to comply with the requisite consignation. The Court of Appeals (CA) affirmed the DARAB's decision, holding that petitioner failed to make a valid tender or consignation of the redemption price within the 180-day period from actual notice of the sale. The Petition: Petitioner seeks review of the CA's decision, raising the issue of whether he validly exercised his right of redemption.
Issue(s)
Whether petitioner Felix Sampilo validly exercised his right of redemption over the subject property. Whether the 180-day period to exercise the right of redemption commenced from the date of actual notice of the sale. Whether petitioner complied with the requirement of tender or consignation of the redemption price.
Ruling
The petition is denied. The Court affirms the ruling of the Court of Appeals, holding that petitioner Felix Sampilo did not validly exercise his right of redemption over the subject property.
Ratio Decidendi
On the validity of the exercise of the right of redemption: The Court affirmed the CA's ruling that petitioner did not validly exercise his right of redemption. Republic Act No. 3844, as amended, governs the rights of agricultural leasehold tenants. Section 12 of R.A. No. 3844 provides the agricultural lessee the right to redeem the landholding if sold to a third person without prior written notice. However, this right must be exercised within 180 days from notice and requires an actual tender or valid consignation of the redemption price. The Court found that petitioner failed on both counts: the filing was beyond the 180-day period from actual notice, and there was no valid tender or consignation. On the commencement of the 180-day period: The Court disagreed with petitioner's contention that no prior written notice was served. It held that petitioner acquired actual notice of the sale on June 2, 2008, during a conference meeting with the Municipal Agrarian Reform Officer. During this meeting, respondent Amistad presented the Extra-Judicial Partition with Sale dated June 14, 2004, and explicitly informed petitioner of the purchase. Therefore, the 180-day period to redeem should be counted from June 2, 2008. Petitioner filed his complaint on December 22, 2008, which was 203 days after this actual notice, thus exceeding the statutory period. On the requirement of tender or consignation: The Court reiterated that an offer to redeem must be accompanied by an actual tender or valid consignation of the entire redemption price. Citing Quiño v. Court of Appeals and Rupa, Sr. v. Court of Appeals, the Court emphasized that a mere intention to repurchase is insufficient. Petitioner failed to make a valid tender of payment or valid consignation of the entire redemption price at the time of filing his complaint. This failure to comply with the essential requisite of tender or consignation rendered his exercise of the right of redemption ineffectual, even if the period had not yet lapsed.
Main Doctrine
The right of redemption of an agricultural tenant under Section 12 of R.A. No. 3844 must be exercised within the 180-day period from actual notice of the sale, and requires not only the filing of a complaint but also an actual tender or valid consignation of the entire redemption price.