G.R. No. L-40257 April 14, 1982
IGLESIA NI CRISTO, petitioner, vs. THE HONORABLE COURT OF APPEALS, HONORABLE ALBERTO A. REYES, et al., respondents.

FACTS

In April 1971, private respondents, claiming to be share-tenants, filed a case in the Court of Agrarian Relations (CAR) to exercise their right of redemption over a parcel of coconut land sold by the original owner to petitioner Iglesia Ni Cristo without their knowledge or prior written notice, allegedly in violation of Section 12 of Republic Act No. 3844 (The Agricultural Land Reform Code). They sought reconveyance of the property. Instead of filing an answer, the petitioner filed a Motion for Bill of Particulars, which was denied by the court commissioner, a ruling later confirmed by the presiding judge. The petitioner then filed a Motion for Reconsideration and to Dismiss, arguing that share-tenants are not agricultural lessees entitled to redeem under the law. This motion was also denied.
Subsequently, the petitioner was declared in default for failure to answer. The CAR proceeded to hear the case ex-parte and rendered a decision in favor of the private respondents, ordering redemption. The petitioner had earlier filed a special civil action for certiorari and prohibition with the Court of Appeals, challenging the denial of its motions as grave abuse of discretion. The Court of Appeals eventually dismissed the petition, prompting this review.

ISSUE

The primary issue is whether share-tenants on coconut lands are considered “agricultural lessees” entitled to exercise the right of redemption under Section 12 of R.A. No. 3844, as amended.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, ruling that share-tenants on coconut lands are indeed agricultural lessees covered by the right of redemption. The Court clarified that R.A. No. 3844, as amended by R.A. No. 6389 (The Code of Agrarian Reforms), explicitly includes all agricultural lands, regardless of tenurial arrangement, within its scope. The law defines “agricultural lessee” to include a person who cultivates the land belonging to another with the latter’s consent, sharing the produce, which encompasses the traditional share-tenancy system.
The legal logic is anchored on the comprehensive intent of agrarian reform legislation to protect all tillers of the soil. The Court rejected the petitioner’s narrow interpretation that would exclude share-tenants, emphasizing that the amendatory law (R.A. No. 6389) removed any distinction and made the right of redemption applicable to all agricultural lessees. Since the land involved is agricultural coconut land and the private respondents were established as share-tenants, they qualify as beneficiaries under the law. Consequently, their right to redeem the land sold without their knowledge was upheld. The Court found no merit in the procedural objections, noting that the CAR decision had become final and executory, and thus saw no reason to disturb the appellate court’s findings.