Facts:

The case involves Leonila Laurel Almeda and Venancio Almeda as petitioners against Eulogio Gonzales and the Honorable Court of Appeals as respondents in G.R. No. L-43800, decided on July 29, 1977. The dispute arises from an agrarian context pertaining to a 46,529-square meter agricultural land in Tanauan, Batangas, devoted to sugar cane and coconuts. Eulogio Gonzales, an agricultural share tenant, was cultivating this land owned by the Angeles family. On September 30, 1968, the Angeles family sold the property to the Almeda spouses without informing Gonzales in writing. The sale was registered with the Register of Deeds of Tanauan on March 27, 1969. Subsequently, Gonzales filed a complaint for redemption on March 27, 1971, with the Court of Agrarian Relations based on Sections 11 and 12 of the Code of Agrarian Reforms. The Almeda spouses contested the complaint, arguing that Gonzales had not made a payment offer or valid judicial consignation at that time. During the hearing on

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Facts:

Background of the Case

• This agrarian case involves the petitioners, Leonila Laurel Almeda and Venancio Almeda, who purchased agricultural land, and the respondent, Eulogio Gonzales, an agricultural share tenant.
• The land, measuring 46,529 square meters and devoted to the cultivation of sugar cane and coconuts, was originally owned by several individuals surnamed Angeles.

Transaction and Notification

• On September 30, 1968, the landowners sold the property to the petitioners without providing written notice of the sale to the tenant-respondent.
• The document of sale was duly registered with the Register of Deeds of Tanauan, Batangas on March 27, 1969.

Filing of the Redemption Complaint

• Relying on Sections 11 and 12 of the Code of Agrarian Reforms, respondent Gonzales filed a complaint on March 27, 1971, seeking the redemption of the land.
• During the proceedings, the parties waived their right to present evidence at trial and agreed instead to submit simultaneous memoranda, upon which the case was decided.

The Agrarian Court’s Ruling

• On October 10, 1973, the Agrarian Court issued a judgment authorizing respondent Gonzales to redeem the land by depositing a redemption price of P24,000.00 with the Clerk of Court within fifteen (15) days.
• Petitioners excepted to this ruling, and the case was subsequently appealed, with the Court of Appeals affirming the Agrarian Court’s decision on January 30, 1976.

Procedural and Legal Issues Raised

• The petition for review was initiated by the petitioners after their motions for reconsideration were denied.
• The case raised three critical questions on:
• The availability of the tenant’s right of redemption on sugar and coconut lands.
• Whether prior tender or judicial consignation of the redemption price is a condition precedent for the valid exercise of the right.
• The jurisdiction of the Court of Agrarian Relations over such redemption cases.

Issue:

Availability of the Right of Redemption

• Does the tenant’s right of redemption under the Code of Agrarian Reforms extend to share tenants in sugar and coconut lands?
• Considering that sugar lands enjoy an exemption in relation to the automatic conversion to agricultural leasehold, is this exemption also applicable to the right of redemption?

Requirement of Valid Tender or Judicial Consignation

• Is the exercise of the tenant’s right of redemption conditioned on the prior tender or judicial consignation of the redemption price?
• What are the implications if such tender or consignation is absent at the time the redemption suit is filed?

Jurisdiction of the Court

• Does the Court of Agrarian Relations (Agrarian Court) have exclusive jurisdiction over suits for redemption arising from agrarian relations, particularly in cases involving sugar and coconut lands?
• Is the Agrarian Court the proper forum for resolving disputes concerning the right of redemption under the Code of Agrarian Reforms?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)