GR L 69477; (May, 1987) (Digest)
G.R. No. L-69477 May 29, 1987
LETICIA GONZALES, petitioner, vs. INTERMEDIATE APPELLATE COURT AND MELCHOR MATIC, respondents.
FACTS
Petitioner Leticia Gonzales owned two parcels of riceland. On May 29, 1974, she entered into a tenancy agreement with private respondent Melchor Matic, making him the agricultural lessee. Subsequently, on July 19, 1974, and December 30, 1975, Gonzales sold the landholdings to Rodolfo Tagle and Isabelita Aldea, respectively. These sales were executed without the knowledge of tenant Melchor Matic and without offering the land to him first, in violation of Section 12 of Republic Act No. 6389 (the Code of Agrarian Reforms).
Upon learning of the sales in November 1981, Matic offered to redeem the lands, but Gonzales refused. Matic then filed a complaint for legal redemption before the Court of Agrarian Relations and consigned the redemption price. The trial court dismissed the complaint, ruling the sales were fictitious, based on Gonzales’s testimony that the low consideration indicated an intent to merely create a trust for her niece and nephew, and that void contracts could not give rise to a right of redemption.
ISSUE
Whether the agricultural lessee, Melchor Matic, has a valid right to redeem the landholdings sold by the landowner to third parties.
RULING
Yes. The Supreme Court affirmed the decision of the Intermediate Appellate Court, sustaining Matic’s right of redemption. The legal logic is anchored on the mandatory statutory right granted to agricultural lessees under Section 12 of R.A. No. 6389 . This provision explicitly grants the lessee the right to redeem the land at a reasonable price if it is sold to a third party without his knowledge. The Court emphasized that this right of redemption is a substantive legal privilege designed to protect tenant-farmers and is superior to any other right of legal redemption.
The Court rejected Gonzales’s claim that the sales were fictitious simulated contracts intended only to create a trust. It ruled that the contracts, being clear and absolute deeds of sale registered resulting in the issuance of new certificates of title, must be given effect as written. A party cannot orally contradict the terms of a written instrument to avoid adverse legal consequences, especially when such a claim would defeat a right created by agrarian law for the protection of tenants. The adequacy or even the existence of consideration is a matter confined to the parties to the sale and cannot be invoked to nullify the tenant’s statutory redemption right. The law’s policy of securing land tenure for tillers prevails over the alleged private arrangements between the landowner and the vendees.