Case Summary (G.R. No. 198770)
Factual Antecedents
Prisco Quirino, Sr. executed a Deed of Conditional Sale on February 27, 1985, transferring ownership of the land to Ernesto Bayagna while reserving a right to repurchase. The sale stipulated a redemption price of P40,000, with a redemption period of eight years, extendable by four years. After more than a decade of possession and cultivation by Ernesto, Prisco attempted to redeem the land in 1996, but Ernesto refused, later allowing Aurelia and Sonia Gua-An to redeem it. Subsequently, Gertrudes Quirino filed a complaint against Ernesto and the Gua-Ans for specific performance and damages due to the disputed redemption rights.
DARAB Ruling
The Department of Agrarian Reform Adjudication Board (DARAB) ruled on December 29, 2004, that Prisco Quirino, Sr. violated agrarian reform laws by abandoning cultivation of the land for over two years, prompting cancellation of his CLT and the allocation of the land to a qualified beneficiary. The DARAB deemed the Deed of Conditional Sale a nullity, claiming Prisco's absence of active ownership as a violation of agrarian reform mandates.
Court of Appeals Ruling
Upon appeal, the Court of Appeals (CA) reversed DARAB's decision, interpreting the conditional sale as an equitable mortgage rather than a prohibited transaction. The CA supported the argument that Prisco's heirs retained a preferential right of redemption due to their prior status as qualified beneficiaries under agrarian reform laws.
Petitioners' Position
In the current petition, the Gua-Ans contended that the CA's ruling misapplied legal principles, primarily arguing that without proper tender and consignation of the redemption money, Gertrudes lacked a valid cause of action. They also maintained that Prisco was not the absolute owner due to violations of pertinent agrarian reform laws, claiming he lost his rights as a farmer-beneficiary upon entering into the transaction with Ernesto.
Legal Framework and Analysis
The ruling heavily relied on the provisions of Presidential Decree No. 27 and Republic Act No. 6657. Under these laws, transfers of landholdings by agrarian reform beneficiaries are strictly prohibited, protecting farmer-tenants as owners of the land they till. The Court emphasized tha
...continue readingCase Syllabus (G.R. No. 198770)
Case Overview
- The case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioners are Aurelia Gua-An and Sonia Gua-An Mamon, while the respondent is Gertrudes Quirino, represented by her son Elmer Quirino.
- The petition challenges the Decision dated February 25, 2011, and Resolution dated September 15, 2011, issued by the Court of Appeals (CA) in CA-G.R. SP. No. 00589-MIN.
- The CA set aside the Department of Agrarian Reform Adjudication Board (DARAB) Decision dated December 29, 2004, which had denied the respondent's claim of preferential right of redemption over certain agricultural landholdings.
Factual Antecedents
- The subject land is a 2.8800-hectare agricultural property located in Batangan, Valencia, Bukidnon, covered by Certificate of Land Transfer (CLT) No. 0-025227 issued to Prisco Quirino, Sr. on October 16, 1979, under Presidential Decree (P.D.) No. 27.
- On February 27, 1985, Prisco executed a Deed of Conditional Sale with Ernesto Bayagna which included a right to redeem the land after eight years with an automatic extension for four more years.
- Prisco failed to redeem the land in 1996, leading Ernesto to allow Aurelia, Prisco’s heir, to redeem the property.
- Following Prisco's death, Gertrudes Quirino filed a complaint against Ernesto and the petitioners for specific performance, redemption, reinstatement,