GR 212778; (April, 2017) (Digest)
G.R. No. 212778. April 26, 2017.
TEDDY CASTRO AND LAURO SEBASTIAN, PETITIONERS, V. PABLITO V. MENDOZA, SR., ET AL. AND MUNICIPALITY OF BUSTOS, BULACAN, RESPONDENTS.
FACTS
Petitioners Teddy Castro and Lauro Sebastian were agricultural tenants of a parcel of land originally owned by the Santos family. In 1992, heir Jesus Santos sold his undivided share of 2,132.42 square meters to the Municipality of Bustos for public market expansion. The municipality constructed the market, inaugurated in August 1994. The surrounding area, including the subject property, had been classified as commercial since 1989. Petitioners filed a complaint before the Provincial Agrarian Reform Adjudicator (PARAD) in August 1994, seeking to exercise rights of pre-emption and redemption under agrarian laws, claiming they were not notified of the sale. The PARAD ruled in their favor, a decision later modified by the DARAB which instead awarded disturbance compensation. The Court of Appeals initially reinstated the PARAD’s redemption order. However, in a subsequent petition for certiorari assailing the PARAD’s execution orders, the CA reversed itself, leading to this petition.
ISSUE
Whether petitioners, as agricultural tenants, retain the right to redeem the land after it has been validly converted to commercial use and a public market has been constructed thereon.
RULING
No. The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the principle that the right of redemption under agrarian laws is extinguished once the land ceases to be agricultural. The property was classified as commercial in 1989, and the Municipality of Bustos validly acquired it for a public purpose—building a public market. The construction was completed and the market inaugurated in 1994. Allowing redemption years after the completion of a public infrastructure project would contravene the doctrine that the government cannot be deprived of property already devoted to public use. The right of redemption is a statutory privilege intended to protect tenancy in agricultural lands. It cannot be invoked to revert property that has already been transformed, in a bona fide manner, for a legitimate public purpose. The law does not intend to restore an agricultural leasehold over land that is no longer agricultural and is already being utilized for a public service. Thus, the PARAD’s orders directing redemption were issued with grave abuse of discretion.