Facts:

• The case involves a 35,916 square meter parcel of land in Sto. Cristo, San Antonio, Nueva Ecija.
• Francisco Garcia claimed to be an agricultural lessee on the land since 1936.
• The land was originally owned by spouses Jose Cruz and Braulia Ortiz, who sold it to their grandson, Lorenzo Bautista, on November 16, 1976.
• Bautista mortgaged the land to Planters Development Bank (PDB) on March 2, 1977.
• Due to Bautista's failure to repay the loan, PDB foreclosed on the mortgage and acquired the property through a public auction.
• The certificate of sale and affidavit of consolidation of ownership were registered on July 11, 1979, and September 25, 1984, respectively.
• PDB was issued Transfer Certificate of Title (TCT) No. NT-185020 on September 25, 1984.
• PDB sold the land to spouses Marciano Ramirez and Erlinda Camacho on July 30, 1986.
• On January 17, 1994, Garcia filed a petition for redemption before the Department of Agrarian Reform Adjudication Board (DARAB) Region III in Cabanatuan City.
• Garcia alleged he was an agricultural lessee and holder of Certificate of Land Transfer (CLT) No. 0-089665 issued on May 26, 1982, and sought to redeem the land.
• The Provincial Adjudicator of DARAB-Cabanatuan City dismissed the petition, but the DARAB Appeal Board reversed this decision.
• The DARAB Appeal Board affirmed the land's coverage under Operation Land Transfer (OLT) pursuant to Presidential Decree No. 27 (PD 27) and declared the sale to PDB null and void.
• The Court of Appeals (CA) affirmed the DARAB Appeal Board's decision, prompting PDB to elevate the case to the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court held that Francisco Garcia was indeed an agricultural lessee of the land.
2. The transfer of the subject land to PDB was valid.
3. Garcia's right to redeem the land h...(Unlock)

Ratio:

• The Supreme Court affirmed that Garcia was an agricultural lessee based on substantial evidence, including the issuance of CLT No. 0-089665 and a written leasehold contract with Braulia Ortiz Cruz.
• The tenancy relationship was not affected by the transfer of ownership to PDB, as the new owner was subrogated to the rights and obligations of the previous agricultural lessors.
• PDB was a mortgagee in good faith, having acquired the property validly under the Torrens system, which allows reliance on the face of the certificate of title.
• Regarding the right of redemption, the Court emphasized that the 180-day period for redemption under Section 12 of RA 3844, as amended by RA 6389, begins from the notice in writing served by the ven...continue reading