Case Digest (G.R. No. 200454)
Case Digest (G.R. No. 200454)
Facts:
Holy Trinity Realty & Development Corporation v. Victorio Dela Cruz, Lorenzo Manalaysay, Ricardo Marcelo, Jr. and Leoncio De Guzman, G.R. No. 200454, October 22, 2014, First Division, Bersamin, J., writing for the Court. Petitioner Holy Trinity Realty & Development Corporation (petitioner) owns a large parcel in Brgy. Dakila, Malolos, Bulacan (the Dakila property). The title originally stood in the name of Freddie Santiago. A number of occupants who had tilled portions of the land executed sinumpaang pahayag in August 1991 surrendering tenancy rights to Santiago in exchange for financial assistance and individual homelots; these surrendered parcels totaled about 4,500 sq. m. Petitioner bought the remaining 208,050 sq. m. from Santiago on September 17, 1992, caused TCTs to be transferred to its name, filled and fenced portions of the land, established field offices, subdivided the tract into six lots and pursued residential subdivision approvals, including Municipal Resolution No. 16-98 (March 4, 1998) reclassifying four lots as residential and securing municipal zoning/conformance clearances.In April 2006, alleged farmers and a barangay agrarian reform council (BARC) chairman requested that the Dakila property be placed under Operation Land Transfer (OLT) coverage under Presidential Decree No. 27; DAR filed a petition with the Provincial Agrarian Reform Adjudicator. On August 18, 2006 the OIC-Regional Director of the Department of Agrarian Reform (DAR) directed that the Dakila titles be placed under the ambit of PD 27/Republic Act No. 6657 (CARL) and instructed MARO/PARO to distribute the parcels to qualified farmer beneficiaries, reserving the right to cancel for misrepresentation. Pending motions, the Register of Deeds issued Emancipation Patents (EPs) transferring the affected TCTs to the respondents, and the DAR Secretary denied petitioner’s appeal on November 22, 2007, upholding the EPs.
Petitioner elevated the matter to the Office of the President (OP). On March 1, 2010 the OP reversed the DAR Secretary, finding the Dakila property had ceased to be agricultural and had been reclassified as residential by Municipal Resolution No. 16-98; the OP concluded the DAR Secretary committed grave abuse of discretion in declaring the property agricultural and ordered reversal of the DAR Secretary’s orders. The respondents sought relief in the Court of Appeals (CA), which on July 27, 2011 reversed the OP and held the Dakila property was agricultural and that reclassification required an ordinance (not a resolution), thereby sustaining DAR’s action. Petitioner filed a petition for review on certiorari in this Court under Rule 45 seeking reinstatement of the OP decision and cancellation of the EPs.
Issues:
- Was the respondents’ petition before the Court of Appeals properly verified and did the CA correctly entertain it?
- May an appellate tribunal address errors not specifically assigned on appeal that are closely related to assigned errors or necessary to render a just decision?
- Was the Dakila property an agricultural land within the coverage of Republic Act No. 6657 or Presidential Decree No. 27 at the time it was placed under agrarian reform coverage?
- Were the issuance of the Emancipation Patents and the DAR’s summary coverage of the Dakila property valid in view of procedural and due process requirements under the agrarian laws?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)