Title
Hidalgo vs. Hidalgo
Case
G.R. No. L-25326
Decision Date
May 29, 1970
Share tenants sought to redeem sold agricultural lands, claiming non-compliance with RA 3844 notice and affidavit requirements. Supreme Court ruled share tenants have redemption rights under the law, reversing the agrarian court’s dismissal.
A

Case Digest (G.R. No. 218964)

Facts:

  • Background of the petitions
    • Two petitions for review challenged decisions of the Court of Agrarian Relations dismissing actions for redemption under Section 12, Republic Act No. 3844.
    • The petitions involved substantially the same issue of law and the same original landowner and vendees; the cases were decided jointly.
  • Parties and landholdings
    • Policarpio Hidalgo was the vendor who executed deeds of sale on September 27, 1963 and March 2, 1964.
    • The vendees were seven private co-respondents named in the petitions, who purchased the parcels from Policarpio Hidalgo.
    • In G.R. No. L-25326 the sold parcel sought to be redeemed measured 22,876 square meters and the deed covered three parcels for a total stated price of P4,000.00.
    • In G.R. No. L-25327 the sold parcel sought to be redeemed measured 7,638 square meters and was sold for P750.00.
  • Status and claims of petitioners
    • In L-25326 petitioners were Igmidio Hidalgo and Martina Rosales, spouses, who alleged they were share tenants working the 22,876-square-meter parcel and averred a fair proportionate worth of P1,500.00 for that parcel.
    • In L-25327 petitioners were Hilario Aguila and Adela Hidalgo, spouses, who alleged they were share tenants working the 7,638-square-meter parcel and sought redemption for P750.00.
    • The parties stipulated that petitioners had been share tenants on the lands for several years.
  • Procedural facts concerning notice, registration and filing
    • No ninety-day written notice of intention to sell, as required by Section 11, R.A. No. 3844, was given by Policarpio Hidalgo to the petitioners.
    • The deeds of sale were recorded in the Registry of Property and registered by the respondents Register of Deeds and Provincial Assessor of Batangas despite the a...(Subscriber-Only)

Issues:

  • Primary legal question presented
    • Whether petitioners, as share tenants, were entitled to redeem the agricultural landholdings they cultivated under the redemption right of Section 12, R.A. No. 3844, despite the absence of prior notice under Section 11 and the vendor's failure to execute the affidavit required by Section 13.
  • Ancillary factual and remedial questions
    • Whether the agrarian court erred in construing the term "agricultural lessee" in Sections 11 and 12 to exclude share tenants still in existence under transitional provisions of the Code.
    • In L-25326, whether the ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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