Case Digest (G.R. No. 149621)
Facts:
Heirs of Francisco R. Tantoco, Sr., et al. v. Hon. Court of Appeals, et al., G.R. No. 149621, May 05, 2006, the Supreme Court Second Division, Azcuna, J., writing for the Court.Petitioners are the heirs of Francisco R. Tantoco, Sr. (originally the co-owners), while respondents include the Court of Appeals, the Department of Agrarian Reform Adjudication Board (DARAB), the Agrarian Reform Beneficiaries Association (ARBA) of San Francisco, Gen. Trias, Cavite, the Register of Deeds for Cavite and the DAR Region IV Director. Petitioners sought annulment of a collective Certificate of Land Ownership Award (CLOA) and its Transfer Certificate of Title (TCT No. CLOA‑1424) allegedly illegally issued to ARBA, and the reinstatement of their TCT No. T‑402203.
The land at issue originally measured some 106.5128 hectares and was in petitioners’ names; after a donation the pertinent area was about 99.3–100 hectares. On May 8, 1989 petitioners offered the land to DAR under the Voluntary Offer to Sell (VOS) scheme at P500,000/hectare (petitioners later claimed they had asked a higher price). DAR sent a Notice of Land Valuation on June 25, 1993 fixing compensation at P4,826,742.35, which petitioners rejected on July 8, 1993 and purportedly withdrew their VOS; petitioners also asked DAR to apply the valuation to another parcel. On July 22, 1993 DAR asked the Land Bank of the Philippines (LBP) to open a trust account for the assessed amount; the LBP certified on July 27, 1993 that the sum had been “reserved/earmarked,” but no cash or LBP bonds were shown to have been paid.
Despite these events, DAR issued a CLOA in favor of ARBA on August 30, 1993 and the Register of Deeds registered TCT No. CLOA‑1424 and cancelled petitioners’ TCT. Petitioners filed for cancellation of the CLOA and reinstatement of their title before the DAR Regional Adjudicator (DARAB Region IV) on November 11, 1994 (DARAB Case No. IV‑Ca‑003‑94). The Regional Adjudicator, on June 17, 1997, declared the property properly covered by CARP, voided and annulled TCT No. CLOA‑1424, directed the Register of Deeds to reinstate petitioners’ TCT No. T‑402203 (subject to retention determinations), and ordered other remedial measures.
DARAB (Quezon City), on consolidated appeals, modified that decision on July 1, 1998: it affirmed some findings but reversed the annulment and affirmed the validity of TCT‑CLOA No. 1424. DARAB denied petitioners’ motions for reconsideration on September 6, 1999. Petitioners then sought relief from the Court of Appeals, which on December 15, 2000 denied the petition; its denial was affirmed on motion for reconsideration dated May 25, 2001. Petitioners filed a Rule 45 petition for review on certiorari to the Supreme Court, alleging among othe...(Pro-only)
Issues:
- Did the Court of Appeals act with grave abuse of discretion when it denied petitioners’ challenge to the DARAB and thereby refuse corrective administrative proceedings?
- Was the subject land properly within the coverage of the Comprehensive Agrarian Reform Program (CARP)?
- Were the DAR/DARAB acquisition and titling procedures and the issuance of the CLOA/TCT fatally defective for failure to observe the requirements of R.A. No. 6657 (including irregular identification of beneficiaries and failure to transfer title to the Republic before awarding)?
- Were petitioners entitled to just compensation before transfer and did the LBP “trust account” con...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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