STATUTORY CONSTRUCTION (Aids to Construction)

CASE: IGMIDIO HIDALGO V POLICARPIO HIDALGO

FACTS:
In the case of Hidalgo versus Hidalgo, respondent-vendor Policarpio Hidalgo
sold parcel land of his agricultural land. Hilario Aguila and Adela Hidalgo, as
tenants thereof, seek by way of redemption the execution of a deed of sale
by respondent-vendor in their favor. They contended that no 90-day notice
of intention to sell the lands for the exercise of the right of pre-emption
prescribed by Section 11 of the Agricultural Land Reform Code was given by
respondent-vendor to the petitioners. The agrarian court rendered identical
decisions dismissing the petitions for redemptions as it concluded that the
right of redemption granted by Section 12 of the Land Reform Code is
available to leasehold tenants only but not to share tenants and that said
provision clearly, definitely, and unequivocally grants said right to the
agricultural lessee and to nobody else.

ISSUE:
Whether or not the petitioners-share tenants are entitled to redeem the land
they are working
HELD:
The court held that where the true intent of the law is clear, such intent or
spirit must prevail over the letter thereof, for whatever is within the spirit of
the statute is within the statute and that adherence to the letter would result
in absurdity like what happened with the agrarian court when they
erroneously fell into several assumptions when they dismissed the petition.
Section 11 of the Land Reform Code, providing for the agricultural lessee’s
preferential right to buy the land he cultivates, provides expressly that the
entire land holding offered for sale must be pre-empted by the if the
landowner so desires unless the majority of the lessees’ object to such
acquisition. The Court further held that taken together with the other
provisions of the Code, the intents, policy and objective is to give both
agricultural lessees and farmers who transitionally continued to be share
tenants the same priority and preferential rights over the lands under their
cultivation, in the event of the acquisition of the lands by expropriation (taken
by government for public use) or voluntary sale, for distribution or resale that
may be initiated by the Land Authority or the National Land Reform Council.
Having provided that, the appealed decisions were reversed thus the
petitions to redeem the land were granted.