Case Digest (G.R. No. 218964)
Facts:
Petitioners Igmidio Hidalgo and Martina Rosales (Case L-25326) and Hilario Aguila and Adela Hidalgo (Case L-25327) sought to redeem agricultural parcels they worked after respondent-vendor Policarpio Hidalgo sold the lands on September 27, 1963 and March 2, 1964; the Court of Agrarian Relations dismissed their petitions under Section 12 of Republic Act No. 3844 on July 19, 1965. In L-25326 the deed covered three parcels for P4,000 and petitioners sought redemption of one parcel for P1,500; in L-25327 the parcel was sold for P750 and petitioners sought redemption for P750; no ninety-day notice under Section 11 nor the affidavit required by Section 13 accompanied the sales, and the redemption actions were filed March 26, 1965 within the two-year period of Section 12.Issues:
- Are share tenants entitled to exercise the right of redemption under Section 12, Republic Act No. 3844?
- Should L-25326 be remanded to determine the reasonable price and consideration for redemption where
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:
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Ratio:
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Doctrine:
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