Case Digest (G.R. No. 226863)
Facts:
- The case involves a dispute over the reallocation of Lot No. 50, BSD-08-000105 (OLT), a portion of Lot 11421, Cad. 256, located in Brgy. Curva, Ormoc City, Leyte.
- The lot was originally registered to Agapito Pongos.
- On December 19, 1974, the lot was awarded to Valeriano C. Dela Corta, Sr. through a certificate of land transfer.
- However, before the Transfer Certificate of Title No. 3247 was issued in Valeriano's favor on February 5, 1998, he had already passed away on June 12, 1989.
- Rebecca Alag-Pitogo filed a petition for reallocation of the subject lot on October 2, 2006, claiming that the lot was erroneously awarded to Valeriano.
- She argued that a decision rendered by the Regional Trial Court (RTC) in CAR Case No. 1726 disqualified Valeriano as a farmer beneficiary and awarded the 1.1000-hectare portion of the lot to Guillerma Alag and Carlos Sabino.
- Guillerma executed an affidavit of waiver in favor of Rebecca due to old age and failing health.
- On August 9, 2007, the Department of Agrarian Reform (DAR)-Region VIII granted Rebecca's petition for reallocation and confirmed her qualifications as a farmer beneficiary.
- The DAR-Region VIII also directed the cancellation of Valeriano's Emancipation Patent and the generation of a new title in favor of Rebecca.
- Pedro Dela Corta, one of Valeriano's heirs, filed a motion for reconsideration, but it was denied.
- The DAR-Region VIII's decision became final and a Certificate of Finality was issued on October 22, 2008.
- Pedro then filed a petition for cancellation of Valeriano's Emancipation Patent before the DAR Adjudication Board (DARAB).
- The DARAB Regional Adjudicator rendered a decision on October 5, 2009, ordering the cancellation of Valeriano's Emancipation Patent and the generation of a new title in favor of Rebecca.
- Pedro appealed to the DARAB Central Office, but his appeal was dismissed for lack of merit.
- Petitioners (Heirs of Dela Corta, Sr.) filed a petition for review with the Court of Appeals (CA), raising issues regarding the validity of the DAR's orders and the failure to implead all the heirs of Valeriano.
- The CA affirmed the DARAB's decision, stating that Valeriano's disqualification as a farmer beneficiary was never contested and that the qualifications of Rebecca as a farmer beneficiary were confirmed by the DAR-Region VIII.
- The CA also held that the other heirs of Valeriano were not indispensable parties in the case.
- Petitioners then filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Case Digest (G.R. No. 226863)
Facts:
The case of Heirs of Dela Corta, Sr. v. Alag-Pitogo involves a dispute over the reallocation of a lot awarded to a deceased farmer beneficiary. The lot in question is Lot No. 50, BSD-08-000105 (OLT), which is a portion of Lot 11421, Cad. 256, located in Brgy. Curva, Ormoc City, Leyte. The lot was originally registered to Agapito Pongos. Pursuant to Presidential Decree No. 27, the lot was awarded to Valeriano C. Dela Corta, Sr. on December 19, 1974. However, before the Transfer Certificate of Title No. 3247 was issued in Valeriano's favor on February 5, 1998, he passed away on June 12, 1989.
On October 2, 2006, Rebecca Alag-Pitogo filed a petition for reallocation of the subject lot with the Department of Agrarian Reform (DAR)-Region VIII. She argued that the lot was erroneously awarded to Valeriano and should be reallocated to her. She claimed that a decision rendered by the Regional Trial Court (RTC), Ormoc City in CAR Case No. 1726 disqualified Valeriano as a farmer beneficiary and awarded the 1.1000-hectare portion of the lot to Guillerma Alag and Carlos Sabino. Guillerma allegedly executed an affidavit of waiver in favor of Rebecca.
The DAR-Region VIII granted Rebecca's petition for reallocation on August 9, 2007. This decision confirmed Rebecca's qualifications as a farmer beneficiary and directed the cancellation of Valeriano's Emancipation Patent. Pedro Dela Corta, one of Valeriano's heirs, filed a motion for reconsideration, but it was denied. The DAR-Region VIII's decision became final and a Certificate of Finality was issued on October 22, 2008.
Pedro then filed an answer with a motion to dismiss before the DARAB, arguing that Rebecca's petition for cancellation was not yet proper for judicial determination as his appeal was still pending before the Office of the DAR Secretary. However, the DARAB Regional Adjudicator ruled against Pedro, ordering the cancellation of Valeriano's Emancipation Patent and the generation of a new title in favor of Rebecca. Pedro appealed to the DARAB Central Office, but his appeal was dismissed for lack of merit.
The heirs of Valeriano, represented by Pedro, filed a Petition for ...