Case Summary (G.R. No. 189570)
Background of the Dispute
Santiago Nisperos and his wife Estefania, who predeceased him, left behind a considerable estate, which included the subject property. Their nine children, including petitioners, claimed shared ownership, stating they collectively tilled the land and paid taxes for it. After Santiago's death, in 1988, a Deed of Donation Mortis Causa was executed in favor of the heirs, but an issue arose when Maria and Cipriana Nisperos executed a VLT in favor of Marissa, who was then a minor. The petitioners alleged that this transfer was fraudulent and initiated legal action upon discovering this in 2001.
Proceedings and Initial Judgments
Following the filing of a complaint by the petitioners alleging fraud and lack of consent for the land transfer, the Department of Agrarian Reform Adjudication Board (DARAB) initially annulled the VLT and the certificate of title issued in Marissa's name. The DARAB's decision was based on the assertion that the transfer was executed without due process of agrarian laws and misrepresented Marissa as a bona fide agrarian reform beneficiary.
Appellate Review and Key issues
Marissa contested the DARAB's ruling, leading to a decision by the Court of Appeals (CA) that reinstated the VLT and upheld the authenticity of the title issued to Marissa. The appellate court dismissed claims of fraud, asserting that sufficient evidence did not support the petitioners' allegations and that the issuance of land title had rendered the claim indefeasible. The CA maintained that the DARAB lacked jurisdiction in ruling on the retention rights of the petitioners and related issues.
Supreme Court Decision
The Supreme Court determined that the complaints should not have been filed with the DARAB, as the jurisdiction properly belonged to the Secretary of the Department of Agrarian Reform. The Court underscored that an agrarian dispute must exist, specifically a tenurial relationship between landowners
...continue readingCase Syllabus (G.R. No. 189570)
Case Background and Legal Framework
- The case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, challenging the decisions of the Court of Appeals (CA) regarding the validity of a Deed of Voluntary Land Transfer (VLT) and the Original Certificate of Title (OCT) issued in favor of Marissa Nisperos-Ducusin.
- The petitioners, heirs of Santiago Nisperos, argue against the CA's affirmation of the Department of Agrarian Reform Adjudication Board (DARAB) decision which upheld the legitimacy of the VLT and the title awarded to the respondent.
Factual Antecedents
- The subject property is a 15,837-square-meter portion of an agricultural land acquired by Santiago Nisperos, the predecessor of the petitioners, and declared for taxation since December 1947.
- Upon the death of Santiago and his wife Estefania, their nine children, including the petitioners, collectively managed and cultivated the land, paying taxes and employing workers.
- In 1988, a Deed of Donation Mortis Causa was executed by two of Santiago's children, Maria and Cipriana, in favor of the petitioners for the entire 58,350-square-meter property.
- A VLT was executed on April 28, 1992, between Maria and Cipriana as landowners and respondent Marissa, who was only 17 at that time, as farmer-beneficiary, leading to the issuance of CLOA and subsequently, OCT in Marissa's name.
Allegations of Fraud and Subsequent Legal Actions
- The petitioners filed a complaint alleging that the transfer of ownership was fraudulent, claiming lack