Case Digest (G.R. No. 76759)
Facts:
The case involves Ramon A. Gonzales as the petitioner and the Land Bank of the Philippines along with the Court of Appeals as respondents. The events leading to this case began with a Deed of Assignment executed on August 8, 1981, by Ramos Plantation Company, Inc., represented by its president, Antonio Vic Zulueta. This deed assigned the corporation's rights under Land Transfer Claim No. 82-757 to Gonzales. Subsequently, Gonzales filed a complaint on December 2, 1986, before the Regional Trial Court of Manila, Branch LI, under Civil Case No. 84-24461, seeking to compel the Land Bank to issue bonds worth P400,000.00 in his name instead of the corporation's name, as the latter was the original owner of the property covered by Transfer Certificate of Title No. T-28755 located in La Suerte, Malang, North Cotabato, which was included in the government's land transfer program. The Land Bank, in its answer, contended that there was no privity of contract between Gonzales...
Case Digest (G.R. No. 76759)
Facts:
Background of the Case:
- Ramon A. Gonzales filed a case against the Land Bank of the Philippines (LBP) and Ramos Plantation Company, Inc. to compel LBP to issue Land Bank Bonds worth P400,000.00 in his name as assignee of Ramos Plantation Company, Inc.
- The assignment was based on a Deed of Assignment executed on August 8, 1981, by Ramos Plantation Company, Inc., assigning its rights under Land Transfer Claim No. 82-757 to Gonzales.
Property in Question:
- The property involved was covered by Transfer Certificate of Title No. T-28755, located in La Suerte, Malang, North Cotabato, with a total area of 251.4300 hectares.
- The property was brought under the government's land transfer program under Presidential Decree No. 27.
Procedural History:
- Ramos Plantation Company, Inc. was declared in default for failing to file an answer.
- LBP filed an answer, arguing that there was no privity of contract between Gonzales and LBP, and that LBP only deals with landowners under the land transfer program.
- The parties submitted a Stipulation of Facts on July 29, 1985, and a Supplemental Stipulation of Facts on September 10, 1985.
- The trial court ruled in favor of Gonzales, ordering LBP to issue the bonds in his name, but the Court of Appeals reversed this decision, stating that the bonds must first be issued to the landowner (Ramos Plantation Company, Inc.) before being endorsed to Gonzales.
Key Facts from the Stipulations:
- Ramos Plantation Company, Inc. had requested LBP to issue the bonds in Gonzales' name, but LBP required compliance with certain conditions.
- Out of nine requirements for the first release of payment, six remained unfulfilled by Ramos Plantation Company, Inc.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Jurisdiction: The existence of a stipulation of facts does not automatically limit the appeal to questions of law if the stipulation is partial and does not cover all relevant facts. Mixed questions of law and fact allow the appeal to proceed to the Court of Appeals.
- Assignability of Rights: While Gonzales, as assignee, stepped into the shoes of Ramos Plantation Company, Inc., the assignment was subject to LBP's rules and restrictions. LBP's policy, as embodied in Resolution No. 75-68, requires bonds to be issued first to the landowner before endorsement to the assignee. This policy is in line with the Land Bank's mandate to deal directly with landowners to streamline the land transfer process.
- Administrative Regulations: Administrative regulations, such as LBP's Resolution No. 75-68, have the force of law and are entitled to respect. They are presumed valid and legal unless proven otherwise.
- Finality of Trial Court's Directive: Since Ramos Plantation Company, Inc. did not appeal the trial court's decision, the directive for it to comply with the six requirements became final and executory. The Supreme Court reinstated this directive, ensuring that Gonzales would receive the bonds once the requirements were met and the bonds were endorsed to him.
Conclusion:
The Supreme Court modified the Court of Appeals' decision, reinstating the trial court's directive for Ramos Plantation Company, Inc. to comply with the six requirements and endorse the Land Bank bonds to Gonzales once issued. The Court upheld LBP's policy of issuing bonds first to the landowner before endorsement to the assignee, emphasizing the validity of administrative regulations and the limitations on the assignability of rights under such regulations.