Case Digest (G.R. No. 199107) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Alfonso Singson Cortal et al. v. Inaki A. Larrazabal Enterprises, decided August 30, 2017 under G.R. No. 199107, the petitioners—Alfonso Singson Cortal, Juanito Singson Cortal, Nenita Codilla, Generoso Pepito Longakit, Ponciana Batoon, and Gregoria Sabroso—were agrarian reform beneficiaries of three parcels of land in Sitio Coob, Barangay Libertad, Ormoc City (Lots 5383-G, ‑N, and ‑F) originally titled to Inaki A. Larrazabal Enterprises. In 1988, under Presidential Decree No. 27 as amended, those parcels were compulsorily acquired, emancipation patents were issued to the petitioners, and payment of just compensation was made to Landbank in the name of the private respondent. In 1999, Larrazabal Enterprises filed an Action for Recovery before the Regional Adjudicator (RAA) of DARAB, alleging that just compensation was neither fixed nor paid, and sought cancellation of petitioners’ titles. The RAA, in an October 15, 1999 decision, restored the titles to Larrazabal Enterprises. Case Digest (G.R. No. 199107) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Land
- Inaki A. Larrazabal Enterprises (private respondent) owned three parcels in Sitio Coob, Barangay Libertad, Ormoc City:
- Lot No. 5383-G (7.6950 ha, TCT No. 10530)
- Lot No. 5383-N (5.7719 ha, TCT No. 10530)
- Lot No. 5383-F (8.7466 ha, TCT No. 16178)
- In 1988, under PD No. 27 (as amended by EO No. 228), the parcels were compulsorily acquired; Emancipation Patents and new TCTs were issued to farmer-beneficiaries, including petitioners (Alfonso S. Cortal et al.).
- Proceedings Before DARAB
- In 1999, Larrazabal Enterprises filed an Action for Recovery against the Department of Agrarian Reform and petitioners before the Regional Adjudicator, DARAB Case No. E.O. 288, alleging no just compensation was fixed or paid.
- Petitioners submitted Landbank certifications showing deposits of P80,359.37 and P95,691.49 in Larrazabal’s name.
- October 15, 1999 Decision by Regional Adjudicator Diloy found no record of payment, ruled in favor of Larrazabal, and ordered restoration of ownership.
- DARAB Reconsideration and Court of Appeals
- Petitioners appealed to DARAB; September 16, 2008 DARAB Decision reversed the 1999 ruling, citing prescription, laches, and Landbank deposits.
- Larrazabal’s MR was granted in the DARAB’s September 30, 2009 Resolution, reinstating the 1999 Decision for denial of due process.
- Petitioners filed a Rule 43 Petition for Review with the Court of Appeals.
- September 30, 2010 CA Resolution dismissed the petition for formal defects:
- Inconsistent listing of petitioner Raymundo Claros Codilla.
- Verification and certification against forum shopping lacked competent evidence of identity.
- Omission of the original DARAB complaint.
- Counsel’s IBP dues receipt lacked place of issue.
- September 7, 2011 CA Resolution denied petitioners’ MR.
- Petitioners sought relief before the Supreme Court via a Petition for Review on Certiorari under Rule 45.
Issues:
- Whether the Court of Appeals erred in dismissing petitioners’ Rule 43 petition for review on purely formal grounds, without considering the merits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)