G.R. No. L-43800 July 29, 1977
LEONILA LAUREL ALMEDA and VENANCIO ALMEDA, Petitioners, vs. THE HONORABLE COURT OF APPEALS and EULOGIO GONZALES, respondents.

FACTS

Respondent Eulogio Gonzales was an agricultural share tenant on a 46,529-square meter land in Tanauan, Batangas, devoted to sugar cane and coconuts, owned by the Angeles family. On September 30, 1968, the landowners sold the property to petitioners-spouses Leonila Laurel Almeda and Venancio Almeda without providing the tenant with the written notice of sale required by law. The deed of sale was registered on March 27, 1969. On March 27, 1971, Gonzales filed a complaint for legal redemption before the Court of Agrarian Relations (CAR) in Lipa City, seeking to redeem the land pursuant to the Code of Agrarian Reforms. The petitioners opposed, arguing that Gonzales was previously offered the land but refused, that he implored them to buy it, and that he failed to make a prior tender or consignation of the redemption price.

ISSUE

The primary issues were: (1) whether the right of legal redemption under agrarian laws extends to tenants on sugar and coconut lands; (2) whether prior tender or judicial consignation of the redemption price is a condition precedent for validly exercising that right; and (3) whether the Court of Agrarian Relations has jurisdiction over such redemption complaints.

RULING

The Supreme Court reversed the Court of Appeals and held that respondent Gonzales did not validly exercise his right of redemption. On the first issue, the Court affirmed that the right of redemption under Sections 11 and 12 of the Agricultural Land Reform Code (RA 3844), as amended, applies to tenants on sugar and coconut lands. This right is a statutory mechanism to bolster security of tenure and promote owner-cultivatorship, and it is not excluded by the fact that sugar lands were initially exempt from automatic leasehold conversion. On the third issue, the Court confirmed that the CAR has original and exclusive jurisdiction, as the case involves a dispute arising from agrarian relations. However, on the decisive second issue, the Court ruled that prior tender of payment or judicial consignation of the redemption price is an indispensable condition for the valid exercise of the right of redemption. Since the Code of Agrarian Reforms is silent on the specific manner of exercising redemption, the suppletory application of the Civil Code requires such tender or consignation. The respondent tenant’s mere filing of the complaint without fulfilling this condition was insufficient. Consequently, his action for redemption failed.