Title
Purificacion vs. Gobing
Case
G.R. No. 191359
Decision Date
Nov 11, 2020
Lucila Purificacion claimed a 1,000-sqm lot as part of disturbance compensation for agricultural land sold in 1993. The Supreme Court ruled her claim barred by prescription, upheld the notarized document, and deemed her adequately compensated with P1,046,460.00.

Case Digest (G.R. No. 191359)
Expanded Legal Reasoning Model

Facts:

  • Parties and Subject Matter
    • Petitioner: Lucila Purificacion, a tenant (together with her late husband, Jacinto Purificacion) of an agricultural land.
    • Respondents: Charles T. Gobing, owner of Charles Builders, Inc., and Atty. Jaime Villanueva, legal counsel for the former landowners.
    • The subject land: A 35,882-square meter parcel covered by Transfer Certificate of Title (TCT) No. T-252445, located in Anabu I, Imus, Cavite, previously owned by the Villanueva family (Elmer Virgil, Francis Andrew, Mine-O Jeno, and Paul Frederick Villanueva).
  • Transaction and Conversion
    • In May 1993, respondent Atty. Villanueva, representing the former landowners, sold 33,882 square meters of the subject lot to respondent Gobing.
    • Respondent Gobing subsequently converted the purchased lot into a residential subdivision known as Gold Lane Subdivision.
    • On July 1, 1993, the Purificacion spouses were paid disturbance compensation amounting to P1,046,460.00 by respondents.
  • Alleged Additional Agreement
    • Lucila Purificacion contended that aside from the payment already received, there existed a mutual agreement with respondents to allocate a 1,000-square meter portion of the subject lot (specifically at the back portion adjacent to a creek) as additional disturbance compensation.
    • Evidence presented by Lucila included:
      • A May 20, 1993 Letter from Atty. Villanueva to Gobing indicating tentative allocation of the 1,000-square meter portion for the Purificacion spouses.
      • An unnotarized Malayang Salaysay stating that the Purificacion spouses, in relinquishing their tenancy rights, were to receive both the cash compensation of P1,046,460.00 and a 1,000-square meter lot.
  • Subsequent Developments and Litigation
    • Despite the alleged agreement, respondents later demanded that Lucila vacate the land, contending that the full disturbance compensation in cash had already been rendered.
    • On January 3, 2000, Lucila filed a Complaint for Disturbance Compensation asserting that the agreement included the additional 1,000-square meter lot, identified as Lot 13, Block 1 of the approved subdivision plan (TCT No. T-463035).
    • Procedural History:
      • February 9, 2001 – The Provincial Agrarian Reform Adjudicator (PARAD) rendered a decision dismissing the claim on the ground of lack of sufficient factual basis and prescription due to the lapse of the three-year period under Section 38, R.A. 3844.
      • September 4, 2001 – PARAD reversed its earlier decision and ordered respondents to effect the transfer of Lot 13, Block 1 as the lawful homelot to the Purificacion spouses.
      • April 8, 2008 – The Department of Agrarian Reform Adjudication Board (DARAB) reversed PARAD’s revised order, reinstating the February 9, 2001 Decision based on the finding that:
        • The tenancy relation was severed upon the conversion of agricultural land to residential land.
ii. The cash compensation paid was more than the statutory minimum required under DAR Administrative Order No. 1, series of 1990. iii. The claim for the 1,000-square meter lot had prescribed, given that the cause of action accrued in July 1993 yet the complaint was filed on January 3, 2000.
  • October 30, 2009 – The Court of Appeals affirmed the DARAB Decision, noting that the additional claim was both barred by prescription and unsupportable by the evidence.
  • February 16, 2010 – Lucila’s Motion for Reconsideration was denied by the Court of Appeals.
  • November 11, 2020 – The Supreme Court, in its decision, affirmed the appellate ruling, concluding that Lucila’s claim was barred and unsubstantial.
  • Evidence and Contentions
    • Documents Presented by Lucila:
      • The May 20, 1993 Letter – indicating consideration for allocation of a 1,000-square meter portion but not conclusively establishing a firm agreement.
      • The Unnotarized Malayang Salaysay – contained a narration similar to the notarized version but with an added claim for the 1,000-square meter lot.
    • Contrasted Evidence:
      • The Notarized Malayang Salaysay dated July 1, 1993, which did not include any provision for the additional 1,000 square meters and enjoyed the presumption of regularity.
    • Respondents’ Argument:
      • The cash disturbance compensation of P1,046,460.00 exceeded the legally mandated minimum, which is calculated as at least five times the average gross annual harvest for the preceding five calendar years.
      • The alleged agreement for the 1,000-square meter allotment was neither substantiated nor conclusively evidenced.
      • Lucila’s claim was filed well beyond the three-year prescriptive period prescribed by law.

Issues:

  • Whether the petitioner's claim to receive an additional 1,000 square meter lot as part of her disturbance compensation is legally valid.
  • Whether the disturbance compensation already paid (P1,046,460.00) fully satisfies the statutory requirement under R.A. 3844 and DAR AO No. 1, series of 1990.
  • Whether Lucila’s cause of action is barred by prescription under Section 38 of R.A. 3844, given the extended delay in filing her complaint.
  • Whether the documentary evidence (the May 20, 1993 Letter and the unnotarized Malayang Salaysay) is sufficient to establish the existence of an agreement for the additional 1,000 square meters.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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