Case Digest (G.R. No. L-13746)
Facts:
The case involves Isidro Bofil and Josefina Dechoso Bofil as plaintiffs and appellants against Catalino P. Casidsid and Eriberto A. Unson as defendants and appellees. The events leading to this case began on August 26, 1948, when the appellants started occupying a parcel of land, Lot No. 166, located in the Guihing Plantation in Padada, Santa Cruz, Davao. This land was administered by the National Abaca and Other Fibers Corporation (NAFCO) under Executive Order No. 29, issued on November 25, 1946. On January 15, 1949, a committee subdividing the plantation awarded Lot No. 166 to the appellants. Subsequently, on March 23, 1949, the NAFCO entered into a lease agreement with the appellants, allowing them to cultivate the land in exchange for a percentage of the gross production.
The land was later partitioned into two lots, with Lot No. 166-A awarded to Isidro Bofil. However, by September 30, 1953, the appellants faced issues with the NAFCO office, which refused to accept the...
Case Digest (G.R. No. L-13746)
Facts:
Occupation and Lease of Lot No. 166
- Since 26 August 1948, the appellants, Isidro Bofil and Josefina Dechoso Bofil, occupied Lot No. 166, a five-hectare parcel of land in the Guihing Plantation, Padada, Santa Cruz, Davao, administered by the National Abaca and Other Fibers Corporation (NAFCO) under Executive Order No. 29 (25 November 1946).
- On 15 January 1949, a committee awarded Lot No. 166 to the appellants.
- On 23 March 1949, NAFCO and the appellants entered into a five-year lease contract, extendible for another five years, with an option to purchase the lot. The lease required the appellants to pay 15% of gross abaca production and 20% of coconut production as rent.
Partition of Lot No. 166
- Lot No. 166 was later partitioned into Lots 166-A and 166-B, each 2.5 hectares. Lot 166-A was awarded to Isidro Bofil, and Lot 166-B to Agustin Bofil, pursuant to a court decision in Civil Case No. 955.
Appellants' Attempt to Purchase the Land
- On 30 September 1953, the appellants wrote to the Board of Liquidators (NAFCO's successor) requesting to purchase Lot No. 166-A under Republic Act No. 477, as the NAFCO office refused to accept their rental payments.
Judgment and Execution Sale
- On 1 June 1956, the Court of First Instance of Davao rendered a judgment in Civil Case No. 1719, ordering the appellants to pay Catalino F. Casidsid (appellee) P2,181.70 for unpaid loans.
- On 27 August 1956, the Provincial Sheriff levied on the appellants' rights, interests, title, and participation in Lot No. 166-A.
- On 27 September 1956, the sheriff sold the appellants' rights in Lot No. 166-A at public auction to Casidsid for P2,330.
- On 1 October 1957, after the redemption period expired, the sheriff executed a certificate of absolute sale in favor of Casidsid.
Appellants' Challenge to the Sale
- On 29 December 1956, the appellants filed a petition to set aside the levy and sale, arguing it violated Section 8 of Republic Act No. 477, which prohibits encumbrance or alienation of lands within ten years from the issuance of a certificate of title.
- On 16 January 1957, the court denied the petition, stating an independent action was required.
- On 23 September 1957, the appellants filed Civil Case No. 2460 to annul the levy and sale.
- On 27 December 1957, the court dismissed the complaint, ruling that Section 8 of Republic Act No. 477 did not prohibit involuntary transfers through levy and execution.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Non-Ownership of Lot No. 166-A
- The appellants did not own Lot No. 166-A, as they had not yet purchased it from the government. Their leasehold rights had expired and were not renewed. Thus, the property could not be levied upon or sold to satisfy a debt.
Protection Under Republic Act No. 477
- Section 8 of Republic Act No. 477 prohibits the encumbrance or alienation of lands acquired under the Act for ten years from the issuance of a certificate of title. It also exempts such lands from liability for debts contracted before the expiration of this period.
- The appellants' right to purchase the land under Section 3 of Republic Act No. 477 is personal and cannot be transferred or assigned. Allowing the levy and sale of such rights would violate the law's intent to ensure that only qualified individuals acquire the land.
Invalidity of Involuntary Transfers
- The Court emphasized that the appellants' rights under Republic Act No. 477 could not be subject to involuntary transfers, such as levy and execution, as this would undermine the law's purpose of protecting the rights of bona fide occupants and veterans.