These consolidated petitions address a dispute over agricultural land where tenant-cultivators sought to exercise their right of redemption. The Supreme Court affirmed that the tenants’ right to redeem the land was valid, even without a formal tender of payment, because the Land Bank of the Philippines (LBP) had issued a certification to finance the redemption. The Court emphasized that the lack of written notice of the sale to the tenants, as required by law, meant the redemption period had not yet begun, securing the tenants’ rights as cultivators-owners under agrarian reform laws.

Can Land Bank Certification Substitute Consignment in Tenant Redemption Rights?

This case revolves around a parcel of agricultural land in Maimpis, San Fernando, Pampanga, specifically Lot No. 3664. The central legal question is whether tenant-cultivators can exercise their right of redemption based on a Land Bank of the Philippines (LBP) certification to finance the redemption, even without a formal tender of payment or consignment of the redemption price, and in the absence of written notice of the land’s sale.

The land was originally owned by spouses Roberto Wijangco and Asuncion Robles, who mortgaged it to the Philippine National Bank (PNB). Due to their inability to pay their debts, PNB foreclosed the mortgage and became the owner of the land. Subsequently, PNB entered into a **Deed of Promise to Sell** with spouses Eligio and Marcelina Mallari. Before the Mallari spouses could fulfill their payment obligations, the tenants of Lot No. 3664 attempted to redeem the property, leading to a legal battle involving the tenants (Arcega, et al.), the Mallari spouses, and PNB.

The tenants filed Agrarian Case No. 1908 seeking to compel the landowners to allow them to redeem their respective landholdings, as provided under Republic Act No. 3844 (The Agricultural Land Reform Code). Initially, the Regional Trial Court (RTC) dismissed the case, arguing that the tenants failed to meet the jurisdictional requirements of Section 12 of R.A. No. 3844. This decision hinged on the RTC’s view that the LBP’s Certification to Finance Redemption was merely conditional and did not constitute valid consignation of the redemption price, and that the petition for redemption was filed beyond the 180-day reglementary period.

However, the Intermediate Appellate Court (now Court of Appeals [CA]) reversed the RTC’s decision, stating that a tender of payment was unnecessary, and that the Land Bank’s Certification was sufficient. The CA also found that the tenants had exercised their right of redemption within the prescribed 180-day period. This decision was elevated to the Supreme Court in **G.R. No. L-61093**, where the Court affirmed the CA’s ruling, emphasizing that the tenants’ right to redeem had not prescribed because the vendee had not provided written notice of the sale, as required by law. Moreover, the Court held that a certification from the Land Bank sufficed for compliance with Section 12 of R.A. No. 3844, as amended.

Despite the Supreme Court’s ruling in **G.R. No. L-61093**, the RTC, in a subsequent decision, again dismissed the tenants’ petition for redemption, disregarding the Supreme Court’s earlier pronouncements. This led to another round of appeals and legal challenges, including the filing of separate complaints by the Mallari spouses seeking the dissolution of the tenancy relationship and payment of back rentals. The Supreme Court, in the present consolidated petitions, reiterated its stance, emphasizing the importance of adhering to its previous rulings. The Court expressed dismay at the RTC’s non-compliance with the **G.R. No. L-61093** decision, asserting that lower courts must obey the decisions of higher courts.

The Court clarified that the LBP’s subsequent cancellation of its earlier Certification did not nullify the rights already acquired by the tenants under R.A. No. 3844, as amended. The Supreme Court also highlighted that the LBP should be impleaded in Agrarian Case No. 1908, given its mandate to finance redemption under Section 12 of R.A. No. 3844, as amended. In light of these considerations, the Supreme Court denied the petitions of the Mallari spouses, affirmed the decisions of the Court of Appeals, granted the petition of the tenants, and ordered the RTC to implead the LBP and proceed with the case to determine the redemption price.

Argument	Position
Necessity of Tender of Payment	The tenants argued that the Land Bank’s certification was sufficient, while the landowners insisted on a formal tender of payment and consignment of the redemption price.
Compliance with Jurisdictional Requirements	The tenants claimed they had complied with all requirements for redemption, while the landowners alleged non-compliance with Section 12 of R.A. No. 3844.
Timeliness of Redemption	The tenants asserted that the redemption was timely because they never received written notice of the sale, while the landowners contended that the period to redeem had already expired.

The Supreme Court’s decision underscores the importance of providing written notice to tenants regarding the sale of land. This notice triggers the 180-day period within which the right of redemption must be exercised. The absence of such notice effectively keeps the right of redemption open. This serves as a protection for agricultural lessees, ensuring they are informed and can exercise their rights under agrarian reform laws. Moreover, the decision affirms that a Land Bank certification to finance the redemption is sufficient compliance with the requirements of Section 12 of R.A. No. 3844, as amended, relieving tenants of the burden of making a formal tender of payment.

FAQs

What was the key issue in this case?	The key issue was whether the tenants could exercise their right of redemption based on a Land Bank certification, without a formal tender of payment or written notice of sale.
Why was written notice important?	Written notice from the vendor triggers the 180-day period for the tenants to exercise their right of redemption. Without it, the redemption period does not commence.
What is the significance of the Land Bank certification?	The Land Bank certification to finance the redemption is deemed sufficient compliance with the redemption requirements, relieving tenants of the need for a formal tender of payment.
What was the RTC’s error in this case?	The RTC erred by disregarding the Supreme Court’s earlier ruling on the same issues and dismissing the tenants’ petition for redemption based on grounds already rejected by the Court.
What did the Supreme Court order the RTC to do?	The Supreme Court ordered the RTC to implead the Land Bank as a party in the case and proceed to determine the reasonable redemption price.
What is the effect of the LBP canceling its certification?	The subsequent cancellation by the LBP of its earlier Certification cannot affect the right already acquired by Arcega, et al. as agricultural lessees under R.A. No. 3844, as amended.
What is res judicata?	Res judicata prevents parties from relitigating issues that have been conclusively determined by a court in a prior case.
What is the next step for the RTC?	The RTC must proceed to determine the reasonable amount of the redemption price, impleading the Land Bank in the process.

This case reinforces the protection afforded to tenant-cultivators under agrarian reform laws, highlighting the importance of written notice and the role of the Land Bank in facilitating land redemption. The Supreme Court’s decision serves as a reminder to lower courts to adhere to established precedents and uphold the rights of agricultural lessees.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Spouses Eligio P. Mallari and Marcelina I. Mallari vs. Ignacio Arcega, G.R. No. 106615, March 20, 2002