Case Digest (G.R. No. 164846)
Facts:
Sta. Monica Industrial and Development Corporation v. The Department of Agrarian Reform Regional Director for Region III, et al., G.R. No. 164846, June 18, 2008, Supreme Court Third Division, Reyes, J., writing for the Court.Private respondent Asuncion Trinidad was the registered owner of several parcels totaling 4.69 hectares in Iba Este, Calumpit, Bulacan. Basilio De Guzman was her agricultural leasehold tenant under a lease executed April 29, 1976; he was later issued Certificates of Land Transfer on July 22, 1981. De Guzman filed a petition with the Department of Agrarian Reform (DAR) Regional Director for the issuance of an emancipation patent; notices were sent to Trinidad, who filed a motion for bill of particulars instead of disclosing a prior sale. The Regional Director granted De Guzman’s petition and ordered the lands placed under Operation Land Transfer and directed issuance of emancipation patents to qualified farmer-beneficiaries.
Trinidad’s motion for reconsideration before the DAR was denied. Trinidad had, however, executed a deed of sale on January 27, 1986 conveying a portion of the property to petitioner Sta. Monica, which thereafter obtained a Transfer Certificate of Title (TCT No. 301408, now RT 70512). After the DAR order, Sta. Monica filed a petition for certiorari and prohibition with the Court of Appeals (CA) arguing it was denied due process because it did not receive the statutorily required notice of coverage under the Comprehensive Agrarian Reform Program (CARP, Republic Act No. 6657, Sec. 16).
In the CA, De Guzman answered that the 1986 sale was void for lack of DAR clearance under Presidential Decree No. 27 (as implemented by DAR Memorandum Circular No. 2‑A), and that Trinidad remained the owner; he also argued Sta. Monica had constructive notice because Trinidad was a corporate officer of Sta. Monica. The CA dismissed Sta. Monica’s petition for lack of merit, holding Sta. Monica was not a real party‑in‑interest because the sale was prohibited and thus ineffective...(Pro-only)
Issues:
- Is Sta. Monica a real party‑in‑interest entitled to challenge the DAR Regional Director’s Order?
- Was Sta. Monica denied due process because it did not receive a separate notice of coverage under RA 6657, Sec. 16?
- Was the sale from Asuncion Trinidad to Sta. Monica valid, or is it void/prohibited under P.D. No. 27 such that the corporate veil should be pierced to treat n...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)