Case Summary (G.R. No. 142439)
Applicable Law
The case primarily invokes Republic Act No. 3844, or the Agricultural Land Reform Code, particularly Section 62, which imposes restrictions on the transfer of agrarian lands for ten years. The relevance of Presidential Decree No. 1474, which reclassified certain lands under the administration of the Department of Agrarian Reform (DAR) from agricultural to residential, commercial, or industrial use, is also critical to the analysis.
Factual Background
Filinvest asserts ownership rights over a parcel of land originally awarded to Ricardo Alvarez. The sale of this land to Mercedes Oliver shortly after the issuance of the title and its subsequent transfer to Filinvest are contested by the heirs of Ricardo Alvarez who claim the sale was void due to alleged violations of transfer restrictions.
Initially, the land was awarded to Ricardo Alvarez by DAR, which included a prohibition against transferring the property for ten years, except to qualified beneficiaries. However, the enactment of Presidential Decree No. 1474 repealed this restriction, allowing landowners within the Laguna Resettlement Project to sell and transfer their properties.
Jurisdictional Issues
The Court must determine if the DARAB had jurisdiction to annul the transfer and whether the petitioners were indeed buyers in good faith. Filinvest claimed ownership following the lawful sale by Mercedes Oliver, arguing that these transactions were valid under the new legal framework post-Presidential Decree No. 1474.
The DARAB, however, initially ruled against Filinvest confirming that the prohibition against the transfer had not been lifted prior to the transactions involved. This ruling was appealed to the Court of Appeals, which upheld the DARAB's decision.
Court of Appeals Decision
The Court of Appeals affirmed the DARAB's conclusion that the sale by Ricardo Alvarez to Mercedes Oliver was invalid, holding that it violated the ten-year transfer prohibition. It additionally ruled that res judicata—stemming from a prior case dismissed for lack of prosecution—barred the respondents from filing their agrarian case against Filinvest.
Supreme Court Ruling
The Supreme Court overturned the decisions of the lower courts, asserting the following:
- Effect of Presidential Decree No. 1474: The Court ruled that the enactment of PD No. 1474 effectively removed the ten-year transfer prohibition associated with the original sale. Therefore, the transfer from Ricardo Alvarez to Mercedes Oliver, and subsequent sale to Filinvest, were valid as they occurred after the repeal of the prohibition.
- Jurisdiction of the DARAB: The Court determined that the DARAB lacked jurisdiction to entertain the annulment and that the case properly belonged to regular courts, considering that the land was reclassified as non-agricultural and no longer under DAR's jurisdiction.
- Incident of Res Judicat
Case Syllabus (G.R. No. 142439)
Case Overview
- This case revolves around a Petition for Review on Certiorari filed by Filinvest Land, Inc. against the Decision of the Court of Appeals, which annulled the sale of a parcel of land (Lot No. 329, GSS-877) originally awarded to Ricardo Alvarez and subsequently transferred to Mercedes Oliver and then to Filinvest.
- The Court of Appeals affirmed the ruling of the Department of Agrarian Reform Adjudication Board (DARAB), which ordered the reversion of the land to the government.
Factual Background
- The subject land is a 16,495 square meter parcel located in Barrio San Vicente, San Pedro, Laguna, which was awarded to Ricardo Alvarez by the Department of Agrarian Reform (DAR) through an Order of Award dated October 9, 1973.
- On August 15, 1977, with his wife's consent, Alvarez purchased the land via a Deed of Sale, which included a restriction against transfer for a period of ten years, except to qualified relatives.
- Presidential Decree No. 1474 was enacted on June 11, 1978, allowing for the conversion of the Laguna Resettlement Project to non-agricultural purposes, effectively repealing the ten-year transfer restriction.
Key Events and Transfers
- On May 25, 1979, Transfer Certificate of Title (TCT) No. 62731 was issued in Alvarez's name.
- On June 10, 1979, Alvarez sold the land to Mercedes Oliver for P10,000, despite her not qualifying as a relative nor being able to cultivate the land.
- On December 22, 1989, Oliver sold the land to Filinvest, which received TCT No. 201836 on January 23, 1990.
Legal Proceedings
- The heirs of Ricardo Alvarez filed a case in the Regional Trial Court (RT