Case Summary (G.R. No. 165073)
Background of the Case
The case involves a petition for certiorari challenging decisions and resolutions by the Court of Appeals related to the agrarian reform coverage of a parcel of agricultural land that was owned by Juan Griao, Sr., who died in 1985. The contested land includes Lot 1505-B in Barangay Gua-an, Leganes, Iloilo, covering 9.35 hectares. Griao owned additional land, having mortgaged a 50-hectare parcel in Sara, Iloilo in the early 1970s, which was later ceded to the Development Bank of the Philippines to satisfy a loan obligation. Presidential Decree No. 27, issued on October 21, 1972, declared the emancipation of tenants from agricultural lands, applicable to Griao’s farm, resulting in Certificates of Land Transfer (CLTs) issued to his tenants.
Initial Actions and Appeals
Following the issuance of CLTs, Griao petitioned for their cancellation, arguing a lack of due process in their issuance and expressing the sentimental value of the land to his family. After his death, the DAR Regional Director dismissed the petition for cancellation, concluding that Griao could retain any land since he possessed other agricultural lands exceeding the specified retention limits. The heirs subsequently sought to retain the 9.35 hectares as per Section 6 of RA 6657, which allows landowners to retain land under certain conditions.
Decisions by the DAR and Court of Appeals
The matter advanced through various administrative orders, with the DAR confirming the issuance of CLTs to the tenants based on PD 27 and later dismissing the heirs' retention application due to standing legal principles asserting that Griao, as the original landowner, was ineligible for retention as he owned other holdings at the time PD 27 became effective. The heirs' appeal to the DAR Secretary was denied on the basis that entitlement for retention lapses when rights are not exercised under PD 27, a view upheld by the Court of Appeals in its October 2003 decision.
Final Ruling and Legal Principles
The Court of Appeals affirmed the decisions stating that the land was tenanted and thus was rightfully included under the coverage of PD 27. Furthermore, the court established that the petition for retention was barred by res judicata as prior orders had become final, highlighting that the heirs did not appeal the DAR’s original decision dismissing Griao’s petition fo
...continue readingCase Syllabus (G.R. No. 165073)
Case Background
- The case revolves around a petition for certiorari challenging the October 17, 2003 Decision and the June 21, 2004 Resolution of the Court of Appeals in CA-GR SP No. 73368.
- Juan Griao, Sr., the deceased owner of a parcel of agricultural land (Lot 1505-B, TCT No. T-53350), measuring 9.35 hectares in Barangay Gua-an, Leganes, Iloilo, is at the center of the dispute.
- Griao also owned a 50-hectare parcel in Barangay Tad-y, Sara, Iloilo, which he mortgaged to the Development Bank of the Philippines (DBP) on February 8, 1972.
- On October 21, 1972, Presidential Decree No. 27 (PD 27) was issued, emancipating tenants from the bondage of the soil and transferring land ownership to them.
Issuance of Certificates of Land Transfer (CLTs)
- Griao’s 9.35-hectare land was placed under PD 27, resulting in the issuance of CLTs to his tenants: Marianito Gulmatico, Ludovico Hubero, Rodolfo Hubero, Placida Catahay, and Roberto Gula.
- Griao petitioned for the cancellation of the CLTs in the early 1980s, asserting he was not given an opportunity to be heard and emphasizing the land's sentimental value and necessity for his family.
- He later offered seven hectares from his 50-hectare land in lieu of the land covered by the CLTs.
Events Following Griao’s Death
- Griao died on July 10, 1985, survived by his wife and seven children. His wife passed away on June 22, 1988, shortly after the enactment of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988.
- The DAR dismissed Griao's petition for CLT cancell