SPS. ELIGIO AND MARCELINA MALLARI VS. COURT OF APPEALS FACTS: Arcega, et al.

are agricultural lessees of landholdings planted to sugarcane described as Lot 3364 of the San Fernando Cadastre. The lot was originally owned by the spouses Wijangco and mortgaged to PNB to secure a loan. For their failure to pay their loan, the PNB foreclosed the mortgage. In the auction sale that followed, PNB was the highest bidder. Later, the spouses Mallari purchased the two lots from PNB without any indication that the same was tenanted. Upon knowledge of the sale, Arcega, et al., who were occupying portions of the land, filed with the Court of Agrarian Relations a Petition for Redemption against the spouses Wijangco, PNB and the spouses Mallari. The case reached the RTC and the latter ordered Arcega, et al. to show cause why the petition should not be dismissed for the tenants' failure to make a tender of payment and/ or consignation of the redemption price. Instead of tendering payment, Arcega, et al. presented a certification entitled "Certification to Finance Redemption of Estate under R.A. No. 3844, As Amended". The RTC dismissed the Petition ruling that the Land Bank certification does not constitute a valid tender of payment and/or consignation of the redemption price. On appeal, the CA reversed the decision of the RTC and remanded the case for further proceedings. Aggrieved, the spouses Mallari filed a Petition for Review. ISSUE: Whether or not the tenants have validly tendered or consigned payment of the redemption price for the purpose of exercising their right of redemption under Section 12, Republic Act No. 3844. HELD: Paragraph 2 of Land Bank Circular No. 3 has made it a mandatory requirement that all proposals for Land Bank financing of land acquisition through pre-emption or redemption must carry the favorable indorsement of the Minister (now Secretary) of Agrarian Reform. It is likewise required that the prescribed form must indicate that the certification has been issued pursuant to a letterrequest from the (DAR Secretary) to the LandBank of the Philippines. The right of redemption under RA No. 3844, as amended is an essential mandate of the agrarian reform legislation to implement the State's policy of owner cultivatorship and to achieve a dignified, selfreliant existence for small farmers. Unfortunately, such laudable policy could not be effected in favor of Ignacio Arcega, et al. since they failed to tender or consign payment of the redemption price. Thus, spouses Mallari should be allowed to continue enjoying their right over the subject property as purchasers thereof, for the State's commendable agrarian reform policy is never intended to unduly transgress the rights of innocent purchasers of lands. VICTOR G. VALENCIA VS. CA G.R. No. 122363, April 29, 2003 FACTS:

Victor Valencia owns two parcels of land situated somewhere in Negros Oriental. He entered into civil law lease agreements with the respondents who include Fr. Andres Flores. The agreement was subject to a prohibition against subleasing or encumbering and against installing a leasehold tenant without Valencia's consent. Fr. Flores designated persons to cultivate the land. Upon the expiration of the lease agreements, Valencia demanded that the respondents vacate the premises but to no avail. He filed a letter of protest to no avail. Twelve years after the filing of the protest, an administrative investigation was finally conducted. The report revealed among others that some of the respondents have even subleased their properties despite the pending protest of Valencia. Valencia's protest was eventually dismissed. Valencia appealed to the CA but it was dismissed for having been filed out of time. His Motion for Reconsideration was also denied. Hence, Valencia elevated the case to the Supreme Court. ISSUE: Whether or not petitioner's civil law lessee, Fr. Flores, may install tenants on the subject premises without express authority to do so under Article 1649 of the Civil Code, especially when the lessee is expressly prohibited from doing so, as in the instant case. HELD: A contract of civil law lease can prohibit a civil law lessee from employing a tenant on the land subject matter of the lease agreement. Section 6 of R.A. No. 3844, as amended, is interpreted to the effect that a civil law lessee cannot automatically institute tenants on the property. The correct view that must necessarily be adopted is that the civil law lessee, although a legal possessor, may not install tenants on the property unless expressly authorized by the lessor. And if a prohibition exists or is stipulated in the contract of lease, the occupants of the property are merely civil law sub-lessees whose rights terminate upon the expiration of the civil law lease agreement.