Third Division SPS. AMADEO CUAÑO and AURORA CUAÑO, Petitioners, -versus-
G.R. No. 107159
COURT OF APPEALS, ET AL., Respondents. X
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The Case This is an appeal via certiorari to reverse the decision of the Court of Appeals which, affirming the judgment of the trial court, held that the private respondents respondents were tenants of the late Andres Cruz and accordingly eligible to exercise a right of redemption in respect of the land they were working on which was sold to petitioner Cuaño spouses.
The Facts The respondents were the tenants of the late Andres Cruz. After the death of the latter, the ownership of the land was passed on to his two daught daughters ers Cecili Cecilia a Cruz-M Cruz-Mendi endiola ola and Carmen Carmen Cruz-D Cruz-Dolo olorr whom whom with withou outt previ previou ouss noti notifi fica cati tion on to privat private e respo respond ndent entss execu execute ted d a contract to sell the land to the Cuaño spouses, the herein petitioner on November 8, 1980. On June 19, 1981, they consummated the sale for a tota totall stat stated ed co cons nsid ider erat atio ion n of PhP7 PhP787 87,5 ,500 00.0 .00 0 agai again n with withou outt the the knowledge of the private respondents. Four days later, on June 23, 1981, spouses Cuaño obtained a loan loan of PhP1 PhP1,5 ,500 00,0 ,000 00.0 .00 0 and, and, to secu secure re that that loan loan,, co cons nsti titu tute ted d a mortgage on the subject land in favor of the lender, First Summa Savings and Mortgage Bank, now known as PAIC Savings and Mortgage Bank (“PAIC”). On June 24 1981, the deed of sale in favor of the Spouses Spouses Cuaño was was regi regist ster ered ed.. On that that same same day, day, Tran Transf sfer er Cert Certif ific icat ates es of Titl Title e covering the five (5) lots into which the original 20.5691 hectares had been divided, were issued in the name of petitioners Spouses Cuaño. On No Nove vemb mber er 1981 1981,, priv privat ate e resp respon onde dent ntss co comm mmen ence ced d suit suit against the Cuaño spouses claiming that, as tenants or agricultural lessees they were entitled to redeem the land pursuant to Section 12 of R.A. No. 3844 ( Known as the Agricultural Land Reform Code) as amended by R.A.6389. On July 5, 1989, the trial court rendered a judgment in favor of the private respondents and said judgment was affirmed by the Court of Appeals in its entirety, hence the herein petition for review.
The Issues 1.
WHETHER OR NOT THERE IS AN EXISTING SHARE TENANCY AND AGRICULTURAL LEASE RELATIONSHIP BETWEEN THE LANDOWNER(S) AND PRIVATE RESPONDENTS?;
2.
WHET HETHER HER OR NOT TH THER ERE E IS AN ELEM ELEMEN ENT TS OF PER PERSON SONAL CULTI CULTIVAT VATION ION BY THE TENAN TENANTS TS OR AGRICU AGRICUTUR TURAL AL LESSEES LESSEES,, CONS CO NSID IDER ERIN ING G TH THAT AT THE ALLE ALLEGE GED D TENA TENANT NTS S HAD HAD AVAI AVAILE LED D THEMSELVES OF THE SERVICES OF THE PAID LABORERS TO CARRY CARRY OUT SOME FARM OPERATIONS?;
3.
WHETH ETHER OR NOT THE ANNOTATION IN THE TRANSFER CERTIFICATES OF TITLE ISSUED IN THE NAME OF THE PETITIONERS THAT THE LAND WAS NOT TENANTED, WAS CONCLUSIVE PROOF THAT NO TENANCY OR AGRICULTURAL AGRICULTURAL LEASEHOLD RELATIONSHIP EXISTED IN RESPECT OF SUCH LAND?
The Court’s Ruling The Supreme Court DENIED the petition and AFFIRMED the decision of the Court of Appeals. The Supreme Court agrees with the Court of Appeals that all the elements of a share tenancy an agricultural lease relationship existed betw betwee een n the the lando andown wner er(s (s)) and and priv privat ate e resp respon onde dent ntss and and that acco accord rdin ingl gly, y, priv privat ate e resp respon onde dent ntss were were shar share e tena tenant ntss and and late laterr agricultural lessees of Andres Cruz and later of his two daughters and ultimately of petitioners Cuaño spouses. As to the issue of whether there is a personal cultivation, the Supreme Court rules that the fact that the tenant did not do all the farm work himself but temporarily or on an emergency basis utilized the service of the others to assist him, was not taken to mean that the tenant had thereby breached the requirement imposed by the statute. As to the issue of the conclusiveness of the annotation, the Supr Supreme eme Co Court urt belie believed ved and held held that that such such anno annotat tatio ion n canno cannott be regarded as conclusive upon the courts of justice as to the legal nature and incidents of the relationship between the landowner(s) in this case and private respondents. And finally, to the right to redeem the land involved, in view of the Supreme Court conclusion that private respondents were share tenants and later agricultural lessees of the owner(s) of that land, it follows that private respondents were entitled to redeem the land upon the alienation thereof by the two daughters of Andres Cruz in favor of the herein petitioner. The right of redemption is statutory in character, that is to say, it is created by and rests upon the provisions of a particular law. It attaches to a particular landholding by operation of law. (Hidalg0 v. Hidalgo 33 SCRA 105, 1970)
Camarines Norte School of Law Brgy. Itomang, Talisay, Camarines Norte
Social Science 6 Submitted by:
Liza Y. Carillo Lovely Borela Anna Corina Belaos Jocelyn Zabala
Ma. Celia De Jesus Instructress
