GR 178591; (March, 2017) (Digest)
G.R. No. 178591 March 29, 2017
SM SYSTEMS CORPORATION (formerly SPRINGSUN MANAGEMENT SYSTEMS CORPORATION), Petitioner vs OSCAR CAMERINO, EFREN CAMERINO, CORNELIO MANTILE, DOMINGO ENRIQUEZ AND HEIRS OF NOLASCO DEL ROSARIO, Respondents
FACTS
Respondents were agricultural tenants on three parcels of land owned by Victoria Homes, Inc. The land was sold to petitioner’s predecessor, Springsun, in 1983 without notifying the tenants. The tenants filed an action for redemption. The RTC and, ultimately, the Supreme Court in a prior final and executory decision ( G.R. No. 161029 ), upheld their right of redemption under agrarian laws. After petitioner refused to accept the redemption money, the respondents deposited the amount with the RTC, which then issued a writ of execution and cancelled petitioner’s titles, transferring them to the respondents.
Subsequently, petitioner entered into a “Kasunduan” or compromise agreement with four of the five respondents (excluding Oscar Camerino), wherein each would receive P300,000.00 in exchange for settling the case. Based on this, petitioner filed a motion to hold the execution in abeyance due to a supervening event. The RTC, however, issued orders invalidating the compromise agreement and denying petitioner’s related motions. The CA dismissed petitioner’s certiorari petition challenging these RTC orders.
ISSUE
Whether the Compromise Agreement is valid and constitutes a supervening event that warrants setting aside the final and executory judgment allowing redemption.
RULING
No, the compromise agreement is void. The Supreme Court affirmed the CA’s dismissal. The right of redemption exercised by the farmer-tenants is a statutory right granted by agrarian reform laws, specifically Republic Act No. 3844 (Agricultural Land Reform Code). This right is personal to the tenant and is intended to uphold the policy of land distribution and farmer empowerment. As such, it cannot be the subject of compromise or conveyance to a third party, as doing so would circumvent the very purpose of the law. The Court cited jurisprudence establishing that a tenant’s right of redemption is inalienable.
The agreement, whereby the tenants would receive a sum of money in lieu of the land, is essentially a waiver or transfer of this inalienable right, making it contrary to law and public policy. Consequently, it produces no legal effect and cannot be considered a supervening event that would modify or stop the execution of the final judgment. The final judgment had already been fully executed with the transfer of titles before the agreement was even conceived. The Court also found no grave abuse of discretion in the RTC judge’s denial of the motion to inhibit, as the orders issued were based on the applicable law and not on bias or partiality.