Case Digest (G.R. No. 248650)
Facts:
- Case: Lim v. Cruz involves a dispute over land transfer and sale under agrarian reform.
- Petitioner: Elizabeth Ong Lim.
- Respondent: Lazaro N. Cruz, represented by his son Vicente T. Cruz.
- Award Date: July 21, 1994, by the Department of Agrarian Reform (DAR).
- Awarded Lands: Two parcels in Calumpit, Bulacan.
- First Parcel: 18,865 square meters, TCT No. 9307/CLOA No. 00243956.
- Second Parcel: 11,099 square meters, TCT No. 9308/CLOA No. 00243955.
- Loan: On April 26, 2000, Lazaro took a loan of P1,500,000.00 from Lim, secured by a Real Estate Mortgage over the first parcel.
- Deed of Sale: On May 9, 2002, Lazaro sold the second parcel to Lim for P1,500,000.00.
- Complaint: On May 12, 2011, Lazaro (represented by Vicente) filed for annulment of the mortgage, deed of sale, and recovery of possession with damages, citing restrictions under RA 6657.
- RTC Ruling: Denied the annulment but reduced mortgage interest to 12% per annum.
- CA Ruling: Affirmed RTC's decision with modifications, voiding the Deed of Sale for violating Section 27 of RA 6657, ordering the return of the land and money.
- Petition: Lim filed a Petition for Review on Certiorari before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the CA's decision that the Deed of Sale is void for violating Section 27 of RA 6657.
- The Supreme Court upheld the RTC's juris...(Unlock)
Ratio:
Jurisdiction:
- The RTC had jurisdiction because the case did not involve an agrarian dispute, which requires a tenancy relationship.
- Only the second element—that the subject matter is agricultural land—was present.
- The relief sought involved private rights adjudication, falling under RTC's jurisdiction.
Validity of Sale:
- Section 27 of RA 6657 prohibits the sale, transfer, or conveyance of awarded lands within ten years from the award, except through hereditary succession, to the government, Land Bank of the Philippines, or other qualified beneficiaries.
- This aims to protect farmer-beneficiaries, ensuring they can possess, cultivate, and enjoy the land.
Pari Delicto:
- The principle does not apply in agrarian reform cases to uphold the policy of agrarian reform.
Outcome:
- The CA's ruling that the Deed of Sale is void was affirmed.
- The respondent may recover the second parcel of land, and the petitioner is entitled to the return of the purchase price with legal interest...continue reading
Case Digest (G.R. No. 248650)
Facts:
The case of Lim v. Cruz revolves around a dispute concerning the transfer and sale of lands awarded under agrarian reform laws. The petitioner, Elizabeth Ong Lim, and the respondent, Lazaro N. Cruz, represented by his son Vicente T. Cruz, are the primary parties involved. On July 21, 1994, Lazaro was awarded two parcels of land in Calumpit, Bulacan by the Department of Agrarian Reform (DAR). The first parcel, covered by Transfer Certificate of Title (TCT) No. 9307/Certificate of Land Ownership Awards (CLOA) No. 00243956, measures 18,865 square meters. The second parcel, covered by TCT No. 9308/CLOA No. 00243955, measures 11,099 square meters.
On April 26, 2000, Lazaro obtained a loan of P1,500,000.00 from Elizabeth Ong Lim and secured it with a Real Estate Mortgage over the first parcel of land. Subsequently, on May 9, 2002, Lazaro executed a Deed of Sale for the second parcel of land in favor of Lim for the same amount. Lazaro handed over the original copies of the TCTs/CLOAs to Lim. On May 12, 2011, Lazaro, represented by Vicente, filed a complaint for annulment of the deed of mortgage, deed of absolute sale, and recovery of possession with damages against Lim, citing the restrictions on the transfer of awarded lands under Republic Act No. (RA) 6657, the Comprehensive Agrarian Reform Law.
The Regional Trial Court (RTC) of Malolos, Bulacan, Branch 78, denied the respondent's prayer to annul the Real Estate Mortgage and the Deed of Sale but reduced the interest rate on the mortgage to twelve percent (12%) per annum. The Court of Appeals (CA) affirmed the RTC's decision with modifications, declaring the Deed of Sale void fo...