SPOUSES AMADEO CUAÑO and AURORA Y. CUAÑO, vs. COURT APPEALS, RENATO CRISTOBAL, VIRGILLO DIEGO, RAMON AREOLA, PEDRO DIONICIO, TERESA ERILLA, LUCIA CUDIA, LUCILA HERNANDEZ, GLICERIA ERILLA, FRANCISCO, CRISTOBAL, FELICISIMO CRISTOBAL, JACINTO CUDIA, EDDIE CAPINPIN, RICARDO CAPINPIN, ALFONSO ANTONIO,…
- G.R. Number: G.R. No. 107159
- Promulgated: 1994-09-26
- Ponente: Feliciano, J.
Doctrine
An annotation or MAR certification on land records is notice of the certification's existence but is not conclusive upon courts as to the legal nature and incidents of relationships between owners and occupants; it does not convert defective instruments into valid ones between parties.
Share tenancy and agricultural lease relations are determined from factual elements showing such relationships; when present, occupants may be entitled to rights attendant thereto, including redemption.
A mortgagee's remedy for a defaulted loan is against its mortgagors and not necessarily against occupants/share tenants; the mortgagee's recourse may thus be personal against the mortgagors.
Facts
Petitioners Cuaño spouses seek reversal of the Court of Appeals decision which affirmed the trial court holding that private respondents were tenants of the late Andres Cruz and could exercise redemption rights over the land sold to petitioners.
In 1956, Andres Cruz acquired a 205,691 sq. m. parcel in Sapang, Jaen, Nueva Ecija, planted with some 100 mango trees.
The trial court ordered that plaintiffs are entitled to redeem, directing the Cuaño spouses to allow redemption within 180 days at P787,500 free of the PAIC mortgage, and to vacate and surrender possession to the plaintiffs as share tenants.
The Court of Appeals and this Court found that the elements of share tenancy and agricultural lease existed between the landowners and private respondents, making respondents share tenants and later agricultural lessees.
Issues
Whether the MAR certification/annotation is conclusive upon the courts as to the legal nature and incidents of the relationship between the registered owners and private respondents.
Whether plaintiffs (private respondents) are entitled to redeem the land and obtain reinstatement/possession as ordered by the trial court and affirmed by the Court of Appeals.
Whether PAIC's recourse for its mortgage loan is against the land or against the mortgagors (the Cuaño spouses).
Whether the redemption price should be the price paid by the Cuaño spouses (P787,500) as the reasonable price at time of sale under Section 12 of R.A. No. 3844, as amended.
Ruling
The petition for review on certiorari (and PAIC's omnibus motion) is denied for lack of merit; the Court of Appeals decision is affirmed and costs are imposed on petitioners.
The trial court judgment declaring plaintiffs entitled to redeem is affirmed: defendants Cuaño spouses must allow redemption within 180 days at P787,500 free of the PAIC mortgage, and must vacate and surrender possession to plaintiffs as share tenants.
PAIC's recourse is not against the land or private respondents but against its mortgagors, the Cuaño spouses.
The Court accepts the Cuaño spouses' valuation of P787,500 as the reasonable price of the land for purposes of Section 12 of R.A. No. 3844, as amended.
Keywords
G.R. No. 107159, right of redemption, agricultural lessee, tenants, mortgagee in good faith, Agricultural Land Reform Code, R.A. No. 3844, R.A. No. 6389, Section 12 of R.A. No. 3844, Lessee's Right of Redemption, Land Bank of the Philippines, contract to sell, deed of sale, Transfer Certificates of Title, Financing Agreement for Agrarian Redemption, legal rate of interest, amortize, cua ntilde, spouses, redemption