Case Summary (G.R. No. 212778)
Background of Property Ownership
The dispute concerns a parcel of land originally owned by the Santos family, specifically covered by Transfer Certificate of Title No. T-20427. After the death of Simeon Santos, the property was partitioned among his surviving heirs, which included a deed of extrajudicial partition and sale executed on May 16, 1977. Petitioners were agricultural tenants of this property, with Teddy Castro assuming tenancy from his mother in July 1981.
Sale of Property and Subsequent Developments
The controversy commenced when one of the heirs, Jesus Santos, sold his share of the property (2,132.42 square meters) to the Municipality of Bustos for the development of a public market. This sale was finalized on October 27, 1992, without prior notification to the petitioners, who later filed a complaint seeking to exercise their rights of pre-emption and redemption under Republic Act No. 3884.
Rulings by PARAD and Subsequent Appeals
On June 28, 1995, the Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of the petitioners, acknowledging their tenancy rights and their entitlement to redeem the property due to the lack of notification regarding the sale. This decision favored the petitioners, leading to an appeal by both the Municipality and Jesus Santos. The Department of Agrarian Reform Adjudication Board (DARAB) confirmed the petitioners' tenant status but modified the PARAD decision, ruling against reinstating possession.
Court of Appeals Decision
Following several appeals, including one to the Court of Appeals (CA), which affirmed the recognition of the petitioners' tenancy, the CA modified the ruling to include moral damages and attorney's fees for the petitioners. Eventually, when petitioners attempted to redeem the property on March 2, 2006, they were met with resistance from the Municipality, leading to further litigation.
Issuances by PARAD and Further Appeals
The PARAD issued further rescheduling on the enforcement of their decision, culminating in a Writ of Execution and a Writ of Possession in 2006, against the Municipality’s various motions to contest these decisions. After diverse challenges, the case was appealed once again, culminating in the CA ruling that the petitioners had no valid right to redeem the property as the required legal procedures were not followed appropriately.
Tribunal's Final Stance
Upon review of the convolutions of the case, the Supreme Court upheld the CA’s decision, asserting that private respondents (as lessees of market stalls) maintained a legitimate interest in the proceedings and warranted intervention. The Supreme Court further ruled th
...continue readingCase Syllabus (G.R. No. 212778)
Case Background
- This case originates from a petition for review on certiorari filed by petitioners Teddy Castro and Lauro Sebastian against private respondents, represented by Pablito V. Mendoza, Sr., and others, collectively known as the Bustos Public Market II Vendors and Stall Owners Association.
- The petition contests the Court of Appeals (CA) Decision in CA-G.R. SP No. 108859, which reversed the rulings of the Provincial Agrarian Reform Adjudicator (PARAD) regarding the right of the petitioners to redeem a portion of land originally owned by the Santos family.
Property Details
- The disputed property is a 2,132.42 square meter parcel of land part of a larger 14,827 square meter area, which was originally covered under Transfer Certificate of Title No. T-20427 registered in the name of Simeon Santos.
- After Simeon's death, his heirs executed a deed of extrajudicial partition, leading to the sale of Jesus Santos' share to the Municipality of Bustos for public market expansion.
Petitioners' Tenancy Claims
- Petitioners have been agricultural tenants of the original Santos property since 1981 and claim their right of redemption under Republic Act No. 3844, as amended.
- They filed a complaint for Maintenance of Peaceful Possession and Redemption before the PARAD on August 22, 1994, asserting their rights as tenants who were not notified of the sale.
PARAD's Initial Rulings
- The PARAD ruled in favor of the petitioners on