Case Digest (G.R. No. 54133)
Facts:
The case involves Teofilo Adrisola as the petitioner against the Honorable Court of Appeals, Feliciano Salamanque, and Segundo Sabio as respondents. The events leading to this case began in Ibayugan, Buhi, Camarines Sur, where Feliciano Salamanque owned a riceland measuring approximately 50 topones. The timeline of the case is crucial, with Salamanque allegedly mortgaging the land to Amando Pinoy in either 1957 or 1975, depending on the party's account. On April 5, 1977, Adrisola filed a complaint for recovery of the landholding and damages before the Court of Agrarian Relations, claiming that he was instituted as a tenant by Pinoy in January 1973 under a 50-50 sharing arrangement. This arrangement transitioned into a registered leasehold contract in early 1976. Adrisola asserted that in September 1976, while he was cultivating the land, Salamanque forcibly took possession of it, claiming to have redeemed the land from Pinoy.
In response, Salamanque and Sabio denied Ad...
Case Digest (G.R. No. 54133)
Facts:
Ownership and Mortgage of the Landholding
- Private respondent Feliciano Salamangue owned a riceland (the Landholding) in Ibayugan, Buhi, Camarines Sur, with an area of "50 topones."
- The land was mortgaged to Amando Pinoy. Petitioner Teofilo Adrisola claimed this occurred in 1957, while Salamangue asserted it was in 1975.
Petitioner’s Claim of Tenancy
- Petitioner alleged that in January 1973, Pinoy instituted him as a tenant on the Landholding under a 50-50 sharing arrangement.
- In early 1976, they entered into a leasehold contract, which was duly registered.
- Petitioner claimed he had been regularly cultivating the land until September 1976, when Salamangue forcibly took possession, claiming to have redeemed the land.
Private Respondents’ Defense
- Private respondents denied the allegations, stating that the Landholding was neither tenanted nor cultivated by an agricultural lessee prior to February 21, 1975.
- They argued that the mortgage to Pinoy included a stipulation prohibiting the institution of a tenant, requiring Pinoy to personally cultivate the land.
- Salamangue notified Pinoy of his intention to redeem the Landholding after the harvest in September 1976.
- Upon redemption, Salamangue instituted Segundo Sabio as the tenant, asserting that Pinoy’s institution of Adrisola as a tenant in August 1976 was in bad faith and violated the mortgage terms.
Administrative Proceedings
- Petitioner filed a complaint for reinstatement with the Department of Agrarian Reform (DAR), which initially declared Sabio as the rightful tenant.
- Petitioner filed another case with the DAR District Office, which later declared him the rightful tenant.
- Private respondents filed a motion for reconsideration, which was pending when petitioner filed the case before the Court of Agrarian Relations (CAR).
Court of Agrarian Relations Decision
- The CAR ruled in favor of petitioner, declaring him the bona fide tenant and ordering his reinstatement.
Court of Appeals Decision
- The Court of Appeals reversed the CAR decision, dismissing the complaint on the grounds that petitioner failed to exhaust administrative remedies and that the mortgage contract prohibited the institution of a tenant.
Issue:
- Whether petitioner Teofilo Adrisola had a cause of action despite failing to exhaust administrative remedies.
- Whether the stipulation in the mortgage contract prohibiting the institution of a tenant was valid and enforceable.
- Whether the institution of petitioner as a tenant by Pinoy violated the mortgage contract.
- Whether the redemption of the Landholding by Salamangue and the subsequent institution of Sabio as tenant were valid.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, ruling in favor of private respondents. The Court held:
- The requirement to exhaust administrative remedies is not absolute and does not apply where the issue is essentially judicial, such as the interpretation of a contractual stipulation.
- The stipulation in the mortgage contract prohibiting the institution of a tenant was valid. The phrase "is the one to transplant" was interpreted to mean that the mortgagee, Pinoy, was required to personally cultivate the land.
- Petitioner’s institution as a tenant by Pinoy violated the mortgage contract. The leasehold contract executed in 1976 was made in bad faith, as Salamangue had already notified Pinoy of his intention to redeem the Landholding.
- Salamangque’s redemption of the Landholding and the institution of Sabio as tenant were valid, as Pinoy could not be considered an "agricultural lessor" or "legal possessor" under the Code of Agrarian Reforms.
Ratio:
- (Unlock)