Case Digest (G.R. No. 106615)
Facts:
Spouses Eligio P. Mallari and Marcelina I. Mallari v. Ignacio Arcega et al., G.R. Nos. 106615, 108591, 109452, 109978 and 139379, March 20, 2002, Supreme Court Third Division, Sandoval-Gutierrez, J., writing for the Court.The dispute concerns Lot No. 3664, San Fernando Cadastre (agricultural, sugarcane), formerly titled to spouses Roberto Wijangco and Asuncion Robles. In March 1962 the Wijangcos mortgaged the property to the Philippine National Bank (PNB); after foreclosure PNB acquired the lots and a Transfer Certificate of Title (TCT No. 154516‑R) was issued in its name. On July 10, 1980, PNB executed a Deed of Promise to Sell covering Lot No. 3664 in favor of spouses Mallari, who paid a 20% down payment and agreed to pay the balance in installments, with PNB retaining title until full payment.
Beginning in 1981 the tenants-cultivators sought to redeem the lot. On July 22, 1981, 27 tenants filed Agrarian Case No. 1908 in the Court of Agrarian Relations (later absorbed by the RTC, Branch 46, San Fernando) to compel the owners/transferees to permit redemption under Republic Act No. 3844 (as amended by R.A. No. 6389). After some compromises and withdrawals, 14 tenants remained as parties (named in the record). The tenants moved the trial court to direct the Land Bank of the Philippines (LBP) to issue a certificate of availability of funds to finance redemption. The RTC initially denied the motion (Dec. 24, 1981) and ordered the tenants to show cause for dismissal for failure to tender/consign the redemption price. The tenants presented an LBP Certification dated January 15, 1982 stating the Bank would finance the redemption if in consonance with law and Bank policy.
On January 27, 1982 the RTC dismissed the petition for redemption, ruling (1) the LBP Certification was conditional and did not constitute valid consignation/tender under Section 12, R.A. No. 3844, and (2) the petition was filed beyond the 180‑day reglementary period. The Court of Appeals reversed, holding the LBP Certification sufficient and that redemption was timely. The Mallaris elevated the CA decision to the Supreme Court in G.R. No. L‑61093; the Supreme Court denied the Mallaris petition in a May 25, 1988 decision, holding the tenants’ right of redemption had not prescribed (no written notice of sale was given) and that a certification from LBP to finance redemption suffices in lieu of tender/consignation, citing the parity between lessee‑preemptioners and lessee‑redemptioners under the Code. Agrarian Case No. 1908 was remanded to the RTC for further proceedings.
Despite that ruling, the RTC (Judge Norberto C. Ponce) later dismissed the tenants’ petition for redemption again (Nov. 8, 1990) and, in other orders, found tenants liable for back rentals (order of June 18, 1990 directing payment of P1,745,777.70 in aggregate). The CA (June 9, 1992) reversed the RTC’s November 8, 1990 dismissal, held the issue on Section 12 had already been decided by this Court, and remanded solely to determine the reasonable redemption price and to implead LBP. The parties then filed multiple petitions to this Court: the Mallaris sought review of the CA decisions (G.R. No. 106615 and others), while the tenants filed a certiorari petition (G.R. No. 108591) attacking several RTC interlocutory orders (turnover/delivery of sheriff’s funds, orders to guard or deliver sugarcane production and denial of reconsideration). Separate DAR proceedings and appeals (Provincial DARAB and DARAB appeals) were held in abeyance pending final resolution of the redemption case. Additional CA and RTC p...(Subscriber-Only)
Issues:
- Under Section 12 of R.A. No. 3844 (as amended), does a Land Bank of the Philippines certification to finance redemption satisfy the jurisdictional requirement of tender of payment or consignation so as to validly exercise the tenants’ right of redemption, and did the tenants’ right to redeem prescribe?
- Were the trial court orders (November 3, 1992; November 12, 1992; December 2, 1992; January 14, 1993) recognizing spouses Mallari’s right to demand back rentals for various crop years valid, or should they be set aside because the tenants validly exercised redemption?
- Did the Court of Appeals err in affirming the DAR Adjudication Board’s decision to hold in abeyance the Provincial DARAB dissolution‑of‑tenancy proceedings pending resolution of the redemption case?
- Did the Court of Appeals err in reversing the RTC orders requiring accounting and delivery of shares for the 1991–1992 crop year?
- Did the Court of Appeals err in setting aside the RTC’s November 4, 1994 ord...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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