GR L 44686; (November, 1982) (Digest)
G.R. No. L-44686 November 19, 1982
MACARIO MANUEL and RODOLFO MANUEL, petitioners, vs. THE HONORABLE COURT OF APPEALS and the HEIRS OF EDUARDO MANUEL, respondents.
FACTS
The case involves a parcel of riceland in Bulacan. The land, originally owned by Irene Manuel, was donated to Emerenciana Manuel, who later sold it to her brother, petitioner Rodolfo Manuel, in 1965. The land had been cultivated for over twenty years by their brother, Eduardo Manuel, as an agricultural lessee. Eduardo remained in possession even after the sale. Upon Eduardo’s death in 1971, his widow, respondent Enriqueta Manuel, and their children continued cultivating the land. The respondents, as Eduardo’s heirs, filed an action to exercise the right of redemption under the Agricultural Land Reform Code. The Court of Agrarian Relations dismissed the action, ruling the right was personal to Eduardo and died with him. The Court of Appeals reversed, declaring Enriqueta the successor agricultural lessee with the right to redeem.
ISSUE
Whether the right of redemption under the Agricultural Land Reform Code is transmissible to the heir of a deceased agricultural lessee, and from what point the redemption period is counted.
RULING
The Supreme Court affirmed the Court of Appeals. The agricultural leasehold relationship is not extinguished by the death of the lessee. Under Section 9 of Republic Act No. 3844 , the leasehold continues with the legal heir who can personally cultivate the land, with the widow being first in the order of preference. Since petitioner Rodolfo, as the new landowner, failed to exercise his right to choose a successor within one month from Eduardo’s death, Enriqueta validly succeeded him as the agricultural lessee. Consequently, she was subrogated to all of Eduardo’s rights, including the right of redemption. The Court further ruled that the two-year redemption period is counted strictly from the date of registration of the sale, not from any alleged actual knowledge of the sale by the lessee. This interpretation gives full effect to the social justice purpose of the agrarian law. The case was remanded for the determination of the redemption price by the Department of Agrarian Reform.