Title
Heirs of Dela Corta, Sr. vs. Alag-Pitogo
Case
G.R. No. 226863
Decision Date
Feb 19, 2020
A dispute arises over the reallocation of a lot awarded to a deceased farmer beneficiary, leading to a legal battle between the heirs of the deceased and a petitioner who claims to be the rightful beneficiary.
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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)

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