G.R. No. 207964 , September 16, 2015
SPOUSES ALFONSO ALCUITAS, SR. (DECEASED-REPRESENTED BY HIS HEIRS) AND ESTELA ALCUITAS (FOR HERSELF AND AS REPRESENTATIVE OF THE HEIRS OF THE DECEASED ALFONSO ALCUITAS, SR.), PETITIONERS, VS. MINVILUZ C. VILLANUEVA, RESPONDENT.

FACTS

Respondent Minviluz C. Villanueva is the registered owner of a parcel of land in Zamboanga del Sur, originally covered by a Free Patent under OCT No. P-32,887. Since June 1988, petitioners Spouses Alfonso Alcuitas, Sr. and Estela Alcuitas have been lessees of the property, operating a gasoline station. On June 22, 1993, Villanueva mortgaged the land to Lucas Datoy to secure a loan. Upon her default, the mortgage was foreclosed under Act No. 3135 . At the public auction, the Spouses Alcuitas bought the property for P201,000.00. After Villanueva failed to redeem it within the one-year period under Act No. 3135 , a definite deed of sale was executed, title was consolidated in favor of the Spouses Alcuitas, and TCT No. T-32,392 was issued in their name. Villanueva later informed the Spouses Alcuitas of her desire to redeem the property for P201,000.00, but they refused. She then tendered and consigned the amount with the Clerk of Court. After failed barangay settlement, Villanueva filed a Complaint for Redemption of Real Property under Commonwealth Act No. 141 against the petitioners before the RTC. The RTC dismissed the complaint, ruling that Villanueva’s right to repurchase under Section 119 of C.A. No. 141 was baseless because the property had been reclassified from agricultural to commercial, and the purpose of the law—to preserve agricultural land for the grantee’s cultivation—was no longer applicable. The CA reversed the RTC, ruling that Villanueva had a clear statutory right to repurchase under Section 119 of C.A. No. 141 , and that mere reclassification of the land did not deprive her of this right, especially as her primary purpose for repurchase was residential.

ISSUE

1. Whether Villanueva has the right to repurchase the subject property from the Spouses Alcuitas under Section 119 of Commonwealth Act No. 141 .
2. Whether Villanueva’s right to repurchase ceased upon the reclassification of the property into a commercial zone.

RULING

The Supreme Court DENIED the petition, affirming the CA’s decision.
1. Yes, Villanueva has the statutory right to repurchase under Section 119 of C.A. No. 141 . The law grants patentees or homesteaders, their widow, or legal heirs the right to repurchase the land within five years from the date of conveyance. The purpose of the law is to preserve the land for the patentee and family, providing them a home and inculcating independence. The Court found that Villanueva exercised her right by filing the complaint, which was equivalent to an offer to repurchase. The Spouses Alcuitas’ argument that the repurchase price was unconscionable due to their improvements was unavailing, as they did not raise this in their answer and their lease contract allowed them to construct improvements at their own expense.
2. No, the reclassification of the property into a commercial zone does not divest Villanueva of her right to repurchase. Section 119 of C.A. No. 141 does not qualify that the right ceases if the property’s classification changes. The law’s policy of preservation for the patentee and family must be liberally construed. The Court distinguished the cited cases (Santana v. Mariñas, Vargas v. Court of Appeals, and Simeon v. Peña), where repurchase was denied because the homesteaders’ motive was speculative profit, not preservation for the family. Here, Villanueva’s primary purpose was for residential use, aligning with the law’s spirit. Allowing reclassification to defeat the right would enable vendees to circumvent the law by converting the property’s use.