Case Digest (G.R. No. 132163)
Facts:
Graciano Padunan v. Department of Agrarian Reform Adjudication Board and Marcos Rodriguez, G.R. No. 132163, January 28, 2003, Supreme Court Third Division, Corona, J., writing for the Court.The dispute concerns three contiguous agricultural parcels in Barangay Bantug, Marawa, Jaen, Nueva Ecija, originally covered by Certificates of Land Transfer (CLTs) in the name of Angelina R. Rodriguez under P.D. No. 27. On July 21, 1981 Angelina executed a Sinumpaang Salaysay waiving her rights in favor of Marcos Rodriguez, a waiver confirmed by the local Samahang Nayon (Kapasyahan No. 15). Thereafter Marcos possessed and cultivated the parcels as tenant‑beneficiary.
On July 21, 1988 Marcos obtained a P50,000 loan from Graciano Padunan, secured by the subject parcels, under a Kasunduan that authorized Padunan to possess and cultivate the land until repayment. Despite the 1981 waiver in favor of Marcos, Emancipation Patents (EPs) Nos. 414430, 414440 and 414448 were issued in Angelina’s name on January 10, 1990. On October 9, 1990 Angelina executed a second waiver/sale in favor of Padunan for P55,000, after which Padunan began asserting ownership and constructing improvements on the land.
Marcos filed an injunction before the Provincial Adjudicator (PARAD) of Nueva Ecija. On August 26, 1991 the PARAD (Hon. Romeo Bello) ruled for Marcos, declaring him the lawful tenant‑beneficiary, directing issuance of corresponding EPs in his name, and ordering Padunan to vacate upon payment of the mortgage debt. Padunan appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which, by decision dated January 27, 1995 (penned by Asst. Sec. Lorenzo R. Reyes), affirmed the PARAD decision in toto. Padunan then petitioned the Court of Appeals, which on August 14, 1997 dismissed his petition for lack of merit, holding among other things that (a) the 1981 waiver and Samahang Nayon confirmation effected a valid substitution in favor of Marcos, (b) Padunan was at best a mortgagee, and (c) annulment of the EPs issued to Angelina was a correction of administrative error within DARAB’s competence.
Padunan filed a petition for review on certiorari under Rule 45 to this Court. He challenged (inter alia) the findings that he was only a mor...(Subscriber-Only)
Issues:
- May the Supreme Court review and overturn the Court of Appeals’ findings of fact in this Rule 45 petition?
- Was petitioner Graciano Padunan only a mortgagee and was Marcos Rodriguez the lawful tenant‑beneficiary of the subject parcels?
- Did the DARAB have jurisdiction to cancel the unregistered Emancipation Patents issued in the name of Angelina Rodriguez, or does the Secretary of the Department of Agrarian Reform have exclusiv...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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