Case Digest (G.R. No. L-3537)
Facts:
The case of Sisenando Arguieta et al. vs. Vicente Corcuera et al. (G.R. No. L-3537) was decided by the Supreme Court of the Philippines on May 21, 1951. The litigation arose from a dispute over the right of the appellants, Sisenando Arguieta and others, to purchase certain parcels of friar lands located in Cavite from the government. The events leading to the case began on October 21, 1927, when the Director of Lands executed a contract of sale for Lot No. 2062 of the Santa Cruz de Malabon Friar Lands Estate in favor of Carlos T. Tirona and Vicente Corcuera for the sum of P7,716, payable in 15 annual installments (Sales Certificate No. 2991). On April 28, 1930, Tirona conveyed his interest in the lot to Corcuera, who continued to cultivate and improve the land. However, due to non-payment of several installments, the Secretary of Agriculture and Commerce canceled the sales contract on March 3, 1937, and instructed the Director of Lands to proceed with the sale of the land u...
Case Digest (G.R. No. L-3537)
Facts:
Background of the Case
- The case involves the alleged right of appellants (Sisenando Arguieta et al.) to purchase certain parcels of friar lands in Cavite from the Government.
- On October 21, 1927, the Director of Lands executed a contract of sale for Lot No. 2062 of the Santa Cruz de Malabon Friar Lands Estate in favor of Carlos T. Tirona and Vicente Corcuera for P7,716, payable in 15 annual installments (Sales Certificate No. 2991).
Transfer of Interest
- On April 28, 1930, Carlos T. Tirona transferred his interest in the lot to Vicente Corcuera, who continued cultivating and improving the land.
Cancellation of the Sale Contract
- Due to failure to pay several annual installments, the Secretary of Agriculture and Commerce canceled the sales contract on March 3, 1937, and instructed the Director of Lands to proceed with the sale of the land under Commonwealth Act No. 32.
- The land was subdivided into smaller lots, which were occupied and cultivated by some of the plaintiffs-appellants, who were tenants of Corcuera.
Re-investigation and Suspension of Cancellation
- On July 29, 1937, the Secretary of Agriculture suspended the effects of the cancellation and ordered a re-investigation.
- Investigations were conducted to determine whether the applicants were bona fide occupants or mere dummies of Corcuera, but no final decision was reached.
Executive Orders and Repurchase
- In 1943, the Philippine Executive Commission issued Executive Orders Nos. 138 and 228, allowing delinquent purchasers of friar lands to repurchase under certain conditions, including full payment of outstanding obligations.
- On January 18, 1944, the Director of Lands decided not to issue a final ruling on the re-investigations, as Corcuera had the right to repurchase under the new executive orders.
- Corcuera fulfilled the conditions, paid the purchase price, and received a final deed of conveyance on April 5, 1944, and subsequently transferred the land to Norberto Lupisan in July 1945.
Plaintiffs' Claims
- On February 10, 1947, the plaintiffs filed a suit seeking annulment of the certificates of title and recognition of their preferential rights to purchase the lots.
- They argued that:
- Upon cancellation of the sale certificate in 1937, the lot reverted to the status of undisposed friar lands under Commonwealth Act No. 32.
- As bona fide occupants, they acquired vested rights to purchase the land.
- Executive Orders Nos. 138 and 228 were null and void, and the sale to Corcuera was invalid.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Finality of Cancellation: The cancellation of the sales certificate in 1937 was not final, as its effects were suspended, and the Bureau of Lands continued to entertain petitions for reconsideration. Therefore, the lot did not revert to the status of undisposed friar lands.
- Vested Rights of Plaintiffs: The plaintiffs' alleged vested rights were based on the assumption that Corcuera's contract had been definitively set aside, which was not the case. Additionally, there was an unresolved issue regarding whether the plaintiffs were bona fide occupants or mere dummies.
- Validity of Executive Orders: Executive Orders Nos. 138 and 228 were valid, as they were enacted for the benefit of private individuals and were not of a political nature. The acts of the Philippine Executive Commission during the Japanese occupation were deemed valid, except those of a political complexion.
- Good Faith Purchaser: The land had been transferred to Norberto Lupisan, who was presumed to be a purchaser in good faith. Parts of the land had also been sold or mortgaged to third parties, further complicating the plaintiffs' claims.
- Equitable Considerations: The plaintiffs' petition was further barred by equitable considerations, as the land had been transferred and encumbered, and the plaintiffs had not addressed these transactions in their claims.