Title
Supreme Court
Filinvest Land, Inc. vs. Adia
Case
G.R. No. 192629
Decision Date
Nov 25, 2015
Land awarded under CARL was unlawfully transferred via affidavits; SC ruled the transfer void under CARL, affirming respondents' possessory rights.

Case Summary (G.R. No. 192629)

Factual Background

Respondents, as registered owners, executed affidavits titled "Pagbibitaw ng Karapatan" (affidavits of waiver) in favor of Filinvest, purportedly relinquishing their rights over the properties for a valuable consideration. They understood that Filinvest would develop the land into a residential subdivision. However, despite their requests for the return of copies of the TCTs and updates on the development plans, they found that their properties were fenced off and unavailable for their use. Consequently, the respondents filed a complaint for recovery of possession and damages against Filinvest.

Proceedings and Judicial Rulings

The RTC ruled in favor of the respondents, asserting their lawful possession of the properties. The RTC ordered Filinvest to vacate the properties, return the original TCTs, and pay attorney’s fees amounting to two hundred thousand pesos. The ruling was affirmed by the CA, which concluded that the respondents had failed to establish the existence of a joint venture agreement (JVA) that could legitimize Filinvest's possession. Furthermore, the CA found that the affidavits presented were void as they contravened Section 27 of the CARL, effectively transferring not just possession but ownership rights over the properties.

Petitioner’s Contentions

Filinvest contended that the affidavits were valid as they merely assigned possessory rights and did not violate the prohibition against transfer set forth in Section 27 of the CARL. They argued that if the court deemed the affidavits void, the respondents must return the consideration they received to avoid unjust enrichment. Additionally, Filinvest claimed that both parties were in pari delicto, having willingly entered into the void transaction.

Respondents' Arguments

The respondents maintained that the affidavits effectively resulted in a prohibited transfer of ownership, thus rendering them void. They asserted that all elements of Article 1416 of the Civil Code necessitating the return of the properties to them were satisfied. They emphasized that no unjust enrichment would occur since Filinvest had illegally occupied their lands for over fifteen years.

The Core Issue

The primary issue in this case is the lawful possession of the disputed properties and whether the affidavits executed by the respondents were valid or null.

Ruling and Legal Considerations

The Supreme Court ruled against Filinvest, determining that the affidavits violated Section 27 of the CARL and were therefore void. This section prohibits any sale, transfer, or conveyance of land awarded under the CARL for ten years after the award, relevant in ensuring that farmer-beneficiaries retain their rights. The decision in Torres v. Ventura established a precedent against any transfer of possessory rights in cases involving agrarian reform.

Application of Pari Delicto Doctrine

The Court rejected Filinvest's argument regarding the pari delicto rule, reaffirming that this doctrine does

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.

About Privacy Terms