AGRARIAN LAW AND SOCIAL LEGISLATION

Atty. Cynthia Arias-Ramos

Krystle Jan Eunice L. Lupango
Student No.: 5190144 | Block: 2 - C
FIDEL TEODORO vs. FELIX MACARAEG AND COURT
OF AGRARIAN RELATIONS
G.R. No. L-20700 February 27, 1969

FACTS:
Felix Macaraeg filed a petition against Fidel
Teodoro, praying that he be maintained as the lawful tenant in
the latter’s landholding, an area of four (4) hectares devoted
to rice culture. Macaraeg alleged that he has worked on the
disputed land “as a tenant for the last seven years,” but he
was forbidden from working on said riceland when Teodoro
placed the new tenant, Jose Niegos, on it. Teodoro, for his
part, denied that Macaraeg was his tenant, claiming that he
had always leased it under civil lease and had never given it
under tenancy.

ISSUE:
Whether or not the “Contract of Lease” entered
into by the parties is a leasehold tenancy agreement.

RULING:
YES, the Supreme Court speaking through
Justice Castro declared that the title, label, or rubric given to
a contract cannot be used to camouflage the real import of an
agreement as evinced by its main provisions. Moreover, it is
basic that a contract is what the law defines it to be, and not
what it is called by the contracting parties.
Reverting to the controverted “Contract of Lease,”
the Court was of the consensus that it indubitably contains the
essential elements of a leasehold tenancy agreement.
Teodoro is the registered owner of the disputed farmholding
and he delivered the possession thereof to Macaraeg in
consideration of a rental certain to be paid in produce.
Evidently, there was a valid leasehold tenancy agreement.

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 AGRARIAN LAW AND SOCIAL LEGISLATION
Atty. Cynthia Arias-Ramos
Krystle Jan Eunice L. Lupango
Student No.: 5190144 | Block: 2 - C
BENEDICTO PADASAS vs. THE HONORABLE COURT
OF APPEALS AND AVELINA M. BENTAJADO
G.R. No. L-35927 March 31, 1978

FACTS:

On June 19, 1968, Benedicto Padasas filed an

action for redemption against Avelina M. Bentajado. He
alleged that, as a tenant of the disputed lot since the Japanese
occupation, the sale on September 28, 1968 by the
Development Bank of the Philippines (DBP) to Bentajado was
without his knowledge and consent in gross violation of his
right of redemption. The foregoing sale became absolute on
May 4, 1970 upon issuance of a Transfer Certificate of Title in
the name of respondent. Bentajado filed a motion to dismiss
the complaint against her on the ground of res judicata.

ISSUE:

Whether or not petitioner may legally redeem the

landholding in question.

RULING:

YES, the Supreme Court ruled that the law is very

clear and explicit that the two-year period to redeem must be
counted from the date of the registration of the sale and no
amount of knowledge or notice can create a legal right as
against the respondent until after the title to the property has
passed to her. While actual notice has been held to be
equivalent to registration in some cases, said doctrine is
inapplicable in view of the definite, decisive and positive
provision of Sec. 12, Republic Act 3844 that the 2-year period
must be counted from the registration of the sale.

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 AGRARIAN LAW AND SOCIAL LEGISLATION
Atty. Cynthia Arias-Ramos
Krystle Jan Eunice L. Lupango
Student No.: 5190144 | Block: 2 - C
The non-registration of the conditional sale in
favor of respondent did not constitute a bar for petitioner to
redeem the property in question after the sale was ultimately
registered. For these reasons, the petitioner may properly
exercise his right of redemption and is entitled to the rentals
only after the date he deposited the redemption price with the
Court of Agrarian Relations on November 3, 1970.