Case Digest (G.R. No. 193747) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Joselito C. Borromeo v. Juan T. Mina, G.R. No. 193747, decided June 5, 2013, the subject is a 1.1057-hectare agricultural parcel (Lot No. 5378, TCT No. EP-43526) in Barangay Magsaysay, Naguilian, Isabela. Respondent Mina obtained an Emancipation Patent No. 393178 from the Department of Agrarian Reform (DAR) on May 2, 1990. Petitioner Borromeo filed two identical petitions before the Provincial Agrarian Reform Office (PARO) on June 9 and September 1, 2003, seeking exemption of the land from coverage under Presidential Decree No. 27 (PD 27) and cancellation of Mina’s patent. Borromeo claimed he purchased the parcel from Serafin M. Garcia by a deed of sale notarized February 19, 1982, that he occupied and tilled the land, and that his total holdings (3.3635 ha) were within retention limits under PD 27 and RA 6647. The Municipal Agrarian Reform Officer (MARO) found the land erroneously recorded under Borromeo’s late father and recommended exemption and refund of Mina’s rental dep Case Digest (G.R. No. 193747) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property and Title
- The subject is a 1.1057-hectare agricultural parcel in Brgy. Magsaysay, Naguilian, Isabela, Lot No. 5378, covered by TCT No. EP-43526 registered to respondent Juan T. Mina.
- Mina’s title is based on Emancipation Patent No. 393178 issued by DAR on May 2, 1990, under PD 27’s Operation Land Transfer (OLT) program.
- Petitioner’s Contentions and Administrative Proceedings
- On June 9, 2003, Joselito C. Borromeo petitioned the PARO to exempt the land from OLT coverage and cancel Mina’s emancipation patent, claiming ownership via a February 19, 1982 deed of sale from Serafin M. Garcia and showing total landholdings of 3.3635 ha within retention limits.
- A second petition filed September 1, 2003 duplicated these allegations. MARO Unblas’s September 29, 2003 Report found the parcel wrongly identified as belonging to petitioner’s father and correctly owned by Garcia, recommended exemption from OLT, cancellation of the patent, and withdrawal of Mina’s rental amortizations.
- Rulings Below
- PARO (undated Resolution) adopted the MARO report, cancelled Mina’s patent, directed lease under RA 3844, and authorized withdrawal of deposited amortizations. Mina appealed.
- DAR Regional Director (Nov. 30, 2004) affirmed exemption but did not cancel the patent, directing Borromeo to seek cancellation before DARAB. Reconsideration was denied Feb. 10, 2006.
- DAR Secretary (DARCO Order No. EXC-0709-333, Sept. 12, 2007) affirmed exemption and upheld findings. Mina filed for CA review.
- Court of Appeals (Apr. 30, 2010) reversed DAR, declaring the 1982 sale void under PD 27 and disallowing collateral attack on Mina’s title under PD 1529 §48; reconsideration denied Sept. 13, 2010.
Issues:
- Whether the sale of the subject property by Garcia to Borromeo in 1982 is valid under PD 27.
- Whether Borromeo may collaterally attack Mina’s registered Emancipation Patent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)