VICENTE PALO-PALO, PETITIONER, VS. INTERMEDIATE APPELLATE COURT, ZOSIMA TAÑO AND JUSTON TAÑO, ABRAHAM PALALON AND AGRIPINA GADIANE, RESPONDENTS.

Palo-Palo versus Intermediate Appellate Court

The Case

This is a petition for review on certiorari brought by Vicente Palo-Palo against the Intermediate Appellate Court, the spouses Juston and Zosima Taño, and the spouses Abraham Palalon and Agripina Gadiane. The petitioner is a tenant farmer who asked the courts to recognize his statutory right of redemption or pre-emption over a parcel of land in Antolang, Siaton, Negros Oriental, after the owners sold it to the private respondents, who then plowed the farm and planted it to corn, effectively dispossessing him. The case matters because both courts below refused him relief on a single procedural ground — that he was bound by the statement in the deed of sale he himself offered in evidence that the property was not tenanted — and the Supreme Court uses the occasion to clarify the limits of that rule and to protect the security of tenure of a tenant who is a stranger to the deed.

Procedural History

Vicente Palo-Palo filed his complaint on the first of July, 1979 before the Regional Trial Court of the Seventh Judicial Region, Branch Thirty-Six, stationed in Dumaguete City. After trial, that court ruled against him, declaring that he could not avail himself of the right of pre-emption of a tenant because he is not a tenant of the property. Its finding rested solely on the ground that the petitioner, like the private respondents, offered in evidence the Deed of Absolute Sale in favor of Abraham Palalon and Agripina Gadiane, and was therefore bound by the statement in that deed that the property is not tenanted.

The petitioner elevated the matter to the then Intermediate Appellate Court, which again rebuffed him, re-echoing the trial court's conclusion that he was bound by the statement in the deed. The appellate court went no further than that pronouncement. Hence the petition for review on certiorari before the Supreme Court, which found the petition impressed with merit.

Facts

The petitioner started his tenancy over the landholding in 1949, when the property was still owned by Zacarias Palacain. In 1965 the property was sold to the spouses Juston and Zosima Taño, who recognized the petitioner's tenancy and continued the arrangement of sharing the harvest from the landholding.

Sometime in October 1978, the spouses Taño sold the property to the private respondents Abraham Palalon and Agripina Gadiane for 1,850 pesos. At first the buyers allowed the petitioner to cultivate the area, but on the twenty-fifth of May, 1979, they plowed the farmholding and planted it to corn, thus effectively dispossessing him of the landholding.

The petitioner then sued to exercise his right of redemption or pre-emption. The private respondents initially contended that he was never a tenant of the property sold, and that in any event the landholding they bought is different from the property he allegedly tenanted. Both points were later settled: a sheriff's report of October 1979, made after inspection, recorded that both parties agreed the land inspected was the same land in question, and the trial court itself noted that there was no more question as to the identity of the land. On the tenancy, the private respondents admitted in their amended answer that the petitioner had been a tenant of the late Zacarias Palacain in the land of the latter — the very land shown to have been sold by the Taños to Abraham and Agripina.

Issues

• Whether or not a party who offers a deed of sale in evidence is conclusively bound by every statement in that document, including the statement that the property is not tenanted, even though he was neither a party nor a signatory to it.
• Whether or not the landholding of which the petitioner claims to be a tenant is the same property sold by the spouses Taño to Abraham Palalon and Agripina Gadiane.
• Whether or not the petitioner is indeed a tenant of the landholding, and may therefore exercise the right of pre-emption or redemption granted to a tenant by law.

Applicable Provisions

The decision applies the right of pre-emption and redemption granted to a tenant under Republic Act Number 3844, as amended by Republic Act Number 6389. The Court does not set out the text of these statutes in the decision; it refers to them as the source of the right it recognizes in the petitioner. The statutory language that the Court does quote and construe is the rule on judicial admissions, which the appellate court invoked against the petitioner:

Section 22, Rule 130, Revised Rules of Court.

This is the provision on which the courts below relied in holding the petitioner bound by the contents of his own exhibit, and the Court's rejection of that reliance is the pivot of the case.

Ruling

On the first issue, the Court held that the petitioner is not bound by the statement in the deed that the property is not tenanted. It is true that he introduced the deed of sale, but he did so solely for the purpose of proving the fact of conveyance of the landholding. His Memorandum of Exhibits and Offer of Evidence declared that he was submitting the deed to show the transfer of the tenanted land from the spouses Taño to the spouses Palalon and Gadiane for the consideration of 1,850 pesos, which fact of conveyance entitled him to exercise the right of redemption. The Court reasoned that the petitioner had to show the fact of transfer, this being an essential requisite before he can claim the right of pre-emption or redemption. And surely, the Court said, the petitioner cannot be bound by the statement in the document that the property is not tenanted, for he was not a party nor a signatory in the transaction and the deed. The appellate court's rule that any party introducing a document is conclusively bound thereby was therefore misapplied.

On the second issue, the Court held that the landholding claimed to be tenanted by the petitioner and the property sold to Abraham and Agripina are one and the same parcel of land. This was already a settled matter even before the trial court decided the case: the deputy sheriff's report of October 1979 recorded the agreement of both parties that the land inspected is the same land in question, and the trial court observed that there was no more question as to the identity of the land after counsel for the defendants himself conceded it.

On the third issue, the Court held that the petitioner is indeed a tenant. This too was settled in the amended answer of the private respondents, wherein they admitted that the plaintiff had been a tenant of the late Zacarias Palacain in the land of the latter — the very land shown to have been sold by the Taños to Abraham and Agripina. With the identity of the landholding and the fact of tenancy established, the Court concluded that there is no further hindrance to the exercise by the petitioner of the right of redemption or pre-emption extended and granted to him by law. Both courts below, the Court said, could have found for the petitioner were they not unduly swayed by the circumstance that he presented as his own evidence the deed of sale containing the statement that the land is not tenanted.

Doctrine

A party who offers a document in evidence is bound by the recitals therein only as they relate to the purpose for which he offers it; he is not conclusively bound by every statement in a deed to which he was neither a party nor a signatory. The rule on judicial admissions, Section 22 of Rule 130, does not convert an exhibit offered to prove one fact into proof of all facts recited in the instrument, especially against a stranger to the transaction.

A tenant who seeks to exercise the right of pre-emption or redemption under Republic Act Number 3844, as amended by Republic Act Number 6389, must establish the fact of conveyance of the landholding, because that transfer is an essential requisite of the right; offering the deed of sale for that purpose does not make him bound by a recital that the land is not tenanted.

Tenancy is a matter that may be settled by the admissions of the landowner, and the identity of the landholding may be settled by the agreement of the parties recorded in a sheriff's inspection report and by the concession of counsel in open court; once both are established, nothing further hinders the tenant's exercise of his statutory right of redemption or pre-emption.

Disposition

The Court set aside the decision under review and entered another recognizing the right of pre-emption or redemption of the petitioner over the subject property in accordance with Republic Act Number 3844, as amended by Republic Act Number 6389. The petitioner won.

Remember This

Memorize this line: a party is not bound by a recital in a deed he offers in evidence when he was neither a party nor a signatory to it, and he offers it only to prove the fact of conveyance that entitles him to redeem. Examiners use this case to test the limits of the rule on judicial admissions and the requisites for a tenant's right of redemption or pre-emption under the agrarian reform statutes.