Facts:

The case involves J. Melliza Estate Development Company, Inc. (petitioner) represented by its director, Atty. Rafael S. Villanueva, against respondents Rosendo Simoy, Gregorio Simoy, and Consejo Simoy. The dispute centers around an application for retention filed by the petitioner concerning a landholding located in Barangay San Jose, San Miguel, Iloilo, specifically Lot No. 665, which spans an area of 87,313 square meters (approximately 8.7313 hectares). This land was registered under Transfer Certificate of Title No. T-76786 in the name of the petitioner. The respondents, who are farmer-beneficiaries, were granted ownership of the land through Emancipation Patents (EPs) issued by the Department of Agrarian Reform (DAR) on August 30, 1998, as evidenced by TCTs EP-7881, EP-7882, EP-7880, and EP-7883.

The petitioner sought to cancel the EPs, asserting its right to retain the land under Presidential Decree No. 27. The Municipal Agrarian Reform Office (MARO) recommended approv...

Facts:

1. Land Ownership and Transfer: J. Melliza Estate Development Company, Inc. (petitioner) owned a landholding identified as Lot No. 665, covering 87,313 square meters (8.7313 hectares) in Barangay San Jose, San Miguel, Iloilo, registered under Transfer Certificate of Title (TCT) No. T-76786.
2. Agrarian Reform Coverage: The land was transferred to respondents Rosendo Simoy, Gregorio Simoy, and Consejo Simoy, who were farmer-beneficiaries under Presidential Decree No. 27 (PD 27). This transfer was evidenced by Emancipation Patents (EPs) issued by the Department of Agrarian Reform (DAR) and registered on August 30, 1998.
3. Application for Retention: Petitioner filed an application for retention on October 17, 2000, seeking to cancel the EPs issued to the respondents. The Municipal Agrarian Reform Office (MARO) and Provincial Agrarian Reform Office (PARO) recommended approval, and the DAR Regional Director granted the application, citing Section 6 of Republic Act (RA) 6657, which allows landowners to retain up to five hectares.
4. Appeals and Denials: Respondents filed a Motion for Reconsideration, arguing that petitioner had already availed of its right of conversion over another landholding. The Regional Director denied the motion, and the DAR Secretary upheld the decision. However, the Office of the President (OP) reversed the DAR Secretary's order, a decision affirmed by the Court of Appeals (CA).

Issue:

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Ruling:

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Ratio:

1. Retention Right Limits: Petitioners who own vast landholdings (more than 50 hectares) are disqualified from exercising retention rights under PD 27 and RA 6657. Petitioner’s ownership of 68.2140 hectares disqualified it from retaining the subject land.
2. Delay and Waiver: Petitioner’s failure to exercise its retention rights within the prescribed period (11 years after the issuance of EPs) constituted waiver and estoppel by laches. Administrative rules allow liberal construction of procedural rules in agrarian cases, prioritizing the welfare of farmer-beneficiaries.
3. Applicability of RA 6657: While RA 6657 grants new retention rights to landowners who did not avail of such rights under PD 27, these rights are subject to qualifications, including landholding limits. Petitioner’s vast landholdings rendered it ineligible for retention.
4. No Vested Rights for Farmer-Beneficiaries: The issuance of EPs to respondents vested them with absolute ownership, and granting petitioner’s retention application would be unjust and prejudicial to the farmer-beneficiaries.