Case Digest (G.R. No. 86044)
Facts:
- Victorino Torres, a farmer-beneficiary, was the leasehold tenant of a 4,000 square-meter parcel of land in Caloocan, Cabatuan, Isabela.
- The land was part of the Florencio Firme Estate.
- In 1978, Torres entered into a "selda" agreement with Leon Ventura due to urgent financial needs, transferring his rights over the land in exchange for a P5,000.00 loan.
- Torres signed an "Affidavit of Waiver" as part of the agreement, relinquishing his rights over the property to Ventura.
- Torres claimed there was an understanding that the land would be returned upon repayment of the loan.
- In 1980, Torres offered to repay the loan, but Ventura requested an extension of one more year.
- By 1981, Torres was unable to repay the loan due to financial constraints.
- In 1985, Torres saved enough money to repay the loan, but Ventura refused to vacate the land.
- Torres filed a complaint with the barangay captain and later with the RTC of Cauayan, Isabela, seeking recovery of possession.
- The RTC ruled in favor of Torres, declaring the affidavit of waiver null and void and ordering Ventura to return the land and pay damages.
- Ventura appealed to the Court of Appeals, which reversed the RTC's decision.
- Torres then filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the agreement between Torres and Ventura was a mortgage.
- The affidavit of waiver executed by Torres was declared null and void.
- The rights and interes...(Unlock)
Ratio:
- The Supreme Court affirmed the RTC's decision, emphasizing the liberal construction of agrarian laws in favor of the farmer-beneficiary.
- The Court found Torres' account more credible, noting it was improbable for him to relinquish land rights he had been cultivating for a long time.
- Repeated offers by Torres to repay the loan indicated his intent to retain ownership.
- The transfer of land rights violated agrarian reform laws, which prohibit the transfer o...continue reading
Case Digest (G.R. No. 86044)
Facts:
The case involves Victorino Torres, a farmer-beneficiary, and Leon Ventura, the respondent. The dispute centers around a 4,000 square-meter parcel of land located in Caloocan, Cabatuan, Isabela, which was part of the Florencio Firme Estate. In 1972, Torres was the leasehold tenant of the land. In 1978, due to urgent financial needs, Torres entered into a "selda" agreement with Ventura, transferring his rights of possession and enjoyment over the land in exchange for a loan of P5,000.00, to be repaid no earlier than 1980. As part of the agreement, Torres signed an "Affidavit of Waiver," relinquishing his rights over the property to Ventura. Torres claimed that it was agreed that upon repayment of the loan, Ventura would return the land to him. In 1980, Torres offered to repay the loan, but Ventura requested an extension of one more year. By 1981, Torres was unable to repay the loan due to lack of funds. It was only in 1985 that Torres saved enough money to make another offer, but Ventura refused to vacate the land. Consequently, Torres filed a complaint with the barangay captain of Magsaysay, Cabatuan, Isabela, and later with the Regional Trial Court (RTC) of Cauayan, Isabela, seeking recovery of possession. The RTC ruled in favor of Torres, declaring the affidavit of waiver null and void, ordering Ventura to return possession of the land, and...