G.R. No. 237583 , January 13, 2021
Felix Sampilo, Petitioner, vs. Eliaquim Amistad and Department of Agrarian Reform Adjudication Board (DARAB Central Office), Respondents.

FACTS

The case involves a 1.9860-hectare parcel of land in Cabasagan, Lala, Lanao del Norte, formerly owned by Claudia Udyang Reble. Petitioner Felix Sampilo was the agricultural lessee of the land under a leasehold tenancy agreement with Reble. On May 29, 2008, Sampilo received a summons for a conference. During the conference on June 2, 2008, respondent Eliaquim Amistad informed Sampilo that he had purchased the land from Reble, as evidenced by an Extra-Judicial Partition with Sale dated June 14, 2004, and demanded that Sampilo vacate the property. On December 22, 2008, Sampilo filed a Complaint for Redemption and Consignation before the Provincial Agrarian Reform Adjudicator, claiming he was a tenant since 2002 and had been paying lease rentals. Amistad moved to dismiss the complaint, arguing failure to state a cause of action, failure to implead Reble, and that the right to redeem had prescribed as more than four years had lapsed since the sale. The Provincial Adjudicator dismissed the complaint, a decision affirmed by the DARAB and later by the Court of Appeals. The DARAB and CA ruled that Sampilo failed to exercise his right of redemption within the 180-day period from notice and failed to make a valid tender or consignation of the redemption price.

ISSUE

Whether petitioner Felix Sampilo validly exercised his right of redemption under Section 12 of Republic Act No. 3844 (Agricultural Land Reform Code).

RULING

No, the Supreme Court denied the petition and affirmed the CA’s decision. The Court held that Sampilo did not validly exercise his right of redemption. First, his 180-day period to redeem commenced on June 2, 2008, when he received actual notice of the sale during the conference, not from a written notice. He filed his complaint on December 22, 2008, which was 203 days later, beyond the statutory period. Second, and more critically, Sampilo failed to comply with the essential requirement of making an actual tender or valid consignation of the entire reasonable redemption price at the time of filing the complaint. Mere intention to redeem, without such tender or consignation, is insufficient. The right of redemption under Section 12 of R.A. No. 3844 requires: (1) the redemptioner must be an agricultural lessee; (2) the land was sold to a third party without prior written notice to the lessee and DAR; (3) only the area cultivated by the lessee may be redeemed; (4) the right must be exercised within 180 days from notice; and (5) there must be an actual tender or valid consignation of the entire reasonable price. Sampilo failed to meet the fourth and fifth requirements. The Court reiterated that an agricultural lessor has the right to sell the property, and the lessee’s remedy is redemption, which must be exercised in strict compliance with the law.