Case Digest (G.R. No. 191359)
Case Digest (G.R. No. 191359)
Facts:
Lucila Purificacion, G.R. No. 191359, November 11, 2020, Supreme Court Third Division, Hernando, J., writing for the Court. Petitioner Lucila Purificacion (Lucila) and her late husband were tenants on a 35,882 sq.m. parcel covered by TCT No. T-252445 in Anabu I, Imus, Cavite formerly owned by members of the Villanueva family. In May 1993, Atty. Jaime Villanueva (representing the Villanueva owners) sold 33,882 sq.m. to Charles T. Gobing (Gobing) who developed the property into Gold Lane Subdivision. On July 1, 1993 Atty. Villanueva paid the Purificacion spouses P1,046,460.00 as disturbance compensation.Lucila later claimed that she and her husband had a separate agreement with the respondents that, in addition to cash, they were to receive a 1,000 sq.m. homelot (identified as Lot 13, Block 1, TCT No. T-463035). As evidence she presented a May 20, 1993 letter from Atty. Villanueva to Gobing and an unnotarized Malayang Salaysay; respondents relied on a Notarized Malayang Salaysay dated July 1, 1993 (notarized July 16, 1993) that acknowledged receipt of P1,046,460.00 but did not mention any 1,000 sq.m. lot.
On January 3, 2000 Lucila filed a Complaint for Disturbance Compensation. The Provincial Agrarian Reform Adjudicator (PARAD) initially rendered a February 9, 2001 Decision dismissing the complaint as time-barred and ordering Lucila to vacate Lot 13. On reconsideration the PARAD issued a September 4, 2001 Order reversing itself and declaring Lot 13 the lawful homelot of the Purificacions, directing transfer of TCT No. T-463035 to Lucila.
Respondents appealed to the Department of Agrarian Reform Adjudication Board (DARAB). In its April 8, 2008 Decision the DARAB reversed the PARAD’s September 4, 2001 Order, reinstating the February 9, 2001 Decision on grounds that (a) tenancy ceased upon conversion to non‑agricultural use, (b) disturbance compensation of P1,046,460.00 exceeded the statutory minimum (per Section 36(1), RA No. 3844 and DAR AO No. 1, s. 1990), and (c) Lucila’s claim had prescribed under Section 38, RA No. 3844. The DARAB denied reconsideration on December 5, 2008.
Lucila filed a Petition for Review with the Court of Appeals (Rule 43), which in an October 30, 2009 Decision affirmed the DARAB: the action was prescribed and, on the merits, Lucila had been properly compensated; the alleged promise of a 1,000‑sq.m. lot was not substantially proven. The CA denied reconsideration in a February 16, 2010 Resolution. Lucila filed the instant Petition for Review with the Supreme Court challenging the CA Decision and its denial of reconsideration.
Issues:
- Did Lucila’s action for additional disturbance compensation prescribe under Section 38 of R.A. No. 3844?
- On the merits, was Lucila entitled to an additional 1,000 sq.m. homelot or was the P1,046,460.00 payment already proper and sufficient under the law and evidence presented?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)