Case Digest (G.R. No. 112526)
Facts:
Sta. Rosa Realty Development Corporation v. Juan B. Amante et al., G.R. Nos. 112526 and 118838, March 16, 2005, Supreme Court Special First Division, Austria‑Martinez, J., writing for the Court.The dispute concerns two contiguous parcels in Barangay Casile, Canlubang Estate, Laguna, covered by Transfer Certificates of Title Nos. 81949 and 84891 (totaling about 254.766 hectares) originally titled in the name of the Yulo family and subsequently in the name of Sta. Rosa Realty Development Corporation (SRRDC). Private respondents (Amante and many co‑claimants) asserted long possession and cultivation of portions of the land since c.1910.
In December 1985 Amante et al. instituted an injunction with damages in the Regional Trial Court (RTC), Laguna (Civil Case No. B‑2333), alleging dispossession by SRRDC security personnel. A preliminary injunction was issued in 1987 but the Court of Appeals (CA) dissolved it in 1988; after trial the RTC dismissed the complaint on January 20, 1992 (ordering plaintiffs to vacate), and on June 28, 1994 the CA affirmed with modification, awarding nominal damages to Amante et al.
Concurrently, SRRDC filed several ejectment actions (MTC Cabuyao → RTC Binan), with mixed results: the MTC initially favored SRRDC (May 24, 1991), the RTC dismissed the ejectment in February 1992 for DAR jurisdiction, and the CA dismissed SRRDC’s petition on January 17, 1995 for failure to show prior physical possession; that CA dismissal became final.
Administratively, the Municipal Agrarian Reform Office issued Notices of Coverage (Aug. 1989) and the DAR issued Notices of Acquisition (Dec. 12, 1989). The Land Bank forwarded valuation folders to the DAR Adjudication Board (DARAB) and, after hearings, the DARAB on December 19, 1991 dismissed SRRDC’s protest, ordered cancellation of the titles, payment by LBP and distribution to identified farmer‑beneficiaries; the titles were cancelled and CLOAs issued (TCT cancellations on Feb. 11, 1992; CLOAs on Feb. 26, 1992). SRRDC sought CA review (CA‑G.R. SP No. 27234) but the CA affirmed DARAB on November 5, 1993.
SRRDC filed a petition for review in the Supreme Court (G.R. No. 112526, filed Nov. 24, 1993). Amante et al. filed G.R. No. 118838 (filed Mar. 2, 1995) seeking relief from previous rulings. The Supreme Court initially rendered a Decision on October 12, 2001 remanding the case to DARAB for re‑evaluation of coverage; a TRO issued Dec. 15, 1993 stayed effects of CLOAs pending final decision. SRRDC filed a second motion for reconsideration; by En Banc R...(Subscriber-Only)
Issues:
- Should the Court grant the second motion for reconsideration and, accordingly, set aside its October 12, 2001 Decision?
- Did the DAR Adjudication Board (DARAB) and the DAR have jurisdiction to determine that the subject parcels were covered by the Comprehensive Agrarian Reform Program (CARP)?
- Are the subject parcels covered by CARP (i.e., are they agricultural and not exempt as park/watershed or otherwise)?
- Are the Certificates of Land Ownership Award (CLOAs) issued to Amante et al. valid and may SRRDC be enjoined from disturbing the beneficiaries’ possession?
- Should the Land Bank tr...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)