G.R. No. 177903 - Heirs of Asuncion vs. Raymundo

On October 3, 1994, respondent Emiliano De Guzman Raymundo filed a Complaint before the Regional Office of the DARAB, Region III, Malolos, Bulacan.
The complaint sought annulment of deeds of sale, cancellation of certificates of title, recovery of possession, and the issuance of a writ of preliminary injunction.
Respondent alleged that he was a tenant on an agricultural land situated in Pandayan, Malcahan, Meycauayan, Bulacan, primarily devoted to palay, with an area of 1.473 hectares covered by OCT No. 01726 originally registered in the name of Patricio Asuncion and Emiliana Floro.

The subject land was placed under the coverage of Presidential Decree (P.D.) No. 27 through the Operation Land Transfer (OLT) Program.
Respondent was included in the master list of agricultural tenants of Bulacan, having been issued a Certificate of Land Transfer (CLT) on July 22, 1981, in his name (CLT No. 0-042717).
In 1989, a document—purportedly an affidavit of waiver—was signed by his mother, Remedios Raymundo, allegedly surrendering her tenancy right over the land, an allegation which the respondent disputed, insisting he never relinquished actual possession.

Respondent later discovered that the heirs of Patricio Asuncion executed an Extrajudicial Settlement of Estate on October 8, 1981, and sold the land to Philippine Ville Development Housing Corporation (Phil-Ville), leading to cancellation of the original title and issuance of new titles (TCT Nos. T-39.627(M) and 39.629(M)).
Phil-Ville subsequently sold the same land to Moldex Products Incorporated, which received new titles (TCT Nos. 93586 and 93587), and Moldex in turn sold portions of the land to Speed Mix, Inc.
Speed Mix proceeded to fence and cement the area and later constructed a building, effectively barring respondent’s access.

On February 22, 1996, the PARAD rendered its decision dismissing the complaint on the ground that Remedios Raymundo’s voluntary surrender extinguished the tenancy rights.
Respondent appealed the PARAD decision to DARAB, which on November 10, 2003, reversed the earlier decision by declaring the deed of conveyance and the “Sinumpaang Salaysay” null and void for violating P.D. No. 27.
The DARAB directed the respondent’s reinstatement on the disputed land, mandated non-cancellation of his CLT, and ordered the generation of an Emancipation Patent (subject to conditions).

The petitioners, including heirs of Patricio Asuncion, Phil-Ville, Moldex, and Speed Mix, elevated the case to the Court of Appeals (CA) via a Petition for Review under Rule 43.
On December 19, 2006, the CA affirmed the DARAB decision, holding that the voluntary surrender executed by Remedios and echoed by respondent was null and void as it contravened P.D. No. 27.
The CA further ruled that the subsequent sale of the land was null and void and that Moldex could not be deemed a purchaser in good faith.
Petitioners moved for reconsideration which was denied in the CA Resolution dated May 16, 2007.
The petitioners contended that respondent’s rights were severed upon his mother’s purported voluntary surrender and through his own affidavit, which the Court ultimately found unconvincing.

Whether the alleged voluntary surrender of tenancy rights by respondent’s mother was valid, given that she was not the recognized tenant on the subject land.
Whether the “Sinumpaang Salaysay” executed by respondent sufficiently demonstrated his intention to surrender his tenancy rights.

Whether the deed of conveyance and the subsequent sales to Phil-Ville, Moldex, and Speed Mix violated the mandatory provisions of P.D. No. 27 regarding the transfer or surrender of agricultural lands.
Whether Moldex Products Incorporated could be considered a buyer in good faith under the restrictions imposed by P.D. No. 27.

The issue of respondent’s continued possession and cultivation of the land despite the controversy over the voluntary surrender document.
Whether the issuance of a CLT to respondent adequately attested to his status as the rightful tenant-farmer under the protective provisions of the Agricultural Land Reform Code (R.A. No. 3844).