Title
Purificacion vs. Gobing
Case
G.R. No. 191359
Decision Date
Nov 11, 2020
Lucila Purificacion claimed a 1,000-sqm lot as part of disturbance compensation for agricultural land sold in 1993. The Supreme Court ruled her claim barred by prescription, upheld the notarized document, and deemed her adequately compensated with P1,046,460.00.
disturbance compensation
prescribed action
proper compensation
A

Case Summary (G.R. No. 191359)

Factual Background

The subject property was a thirty-five thousand eight hundred eighty-two (35,882) square meter parcel of agricultural land covered by TCT No. T-252445, located at Anabu I, Imus, Cavite. It was formerly owned by Elmer Virgil Villanueva, Francis Andrew Villanueva, Mine-O Jeno Villanueva, and Paul Frederick Villanueva (the former landowners). Lucila and her late husband Jacinto were tenants of the subject lot.

In May 1993, Atty. Jaime Villanueva sold thirty-three thousand eight hundred eighty-two (33,882) square meters of the subject land to Charles T. Gobing (of Charles Builders, Inc.). Gobing converted the purchased portion into a residential subdivision known as Gold Lane Subdivision. On July 1, 1993, Atty. Villanueva paid the Purificacion spouses P1,046,460.00 as disturbance compensation.

Lucila later contended that, aside from the P1,046,460.00 cash payment, she and her husband had a mutual agreement with respondents that they would relinquish their tenancy rights except for a 1,000-square meter portion where their house stood, as part of the disturbance compensation. She supported her claim through a May 20, 1993 Letter and an unnotarized Malayang Salaysay.

Respondents disputed the existence and enforceability of any additional agreement to give Lucila a 1,000-square meter portion. They asserted that Lucila had already been fully compensated in cash and relied on the existence of a Malayang Salaysay dated July 1, 1993, which, according to respondents, was notarized on July 16, 1993 (the Notarized Malayang Salaysay). Respondents emphasized that Lucila’s own notarized statement did not mention any additional 1,000-square meter grant.

The Parties’ Claims and Evidence

Lucila’s position was that she had an enforceable entitlement to (1) cash disturbance compensation of P1,000,000.00 plus (2) a 1,000-square meter lot identified as Lot 13, Block 1 of the approved subdivision plan, covered by TCT No. T-463035 in the name of Charles Builders Co., Inc., represented by Gobing. She alleged that respondents promised the additional land, and that respondents failed to fulfill it when Gobing demanded that Lucila vacate.

To substantiate her claim, Lucila presented the May 20, 1993 Letter, which stated that the 1,000 square meters would be allocated at the back portion of the property adjacent to the creek, and the unnotarized Malayang Salaysay, which described the transaction as being “in exchange” for P1,046,460.00 and 1,000 square meters of land, among other statements.

Respondents, on the other hand, argued that Lucila had no right to demand any additional disturbance compensation. They cited the legal basis that disturbance compensation for dispossessed tenants displaced by conversion to non-agricultural use is computed at a minimum of five (5) times the average gross annual harvest value for the last five preceding calendar years, as guided by DAR AO No. 1, series of 1990 and the relevant provisions of R.A. No. 3844. They also relied on the Notarized Malayang Salaysay, which—according to respondents—contained the relinquishment of tenancy rights in exchange for P1,046,460.00, and did not mention any 1,000-square meter additional entitlement.

Proceedings Before the PARAD: Initial Dismissal and Subsequent Reversal

On January 3, 2000, Lucila filed a Complaint for Disturbance Compensation. In the complaint, she invoked the alleged agreement for an additional 1,000-square meter portion as part of disturbance compensation.

On February 9, 2001, the Provincial Agrarian Reform Adjudicator (PARAD) rendered a decision for respondents. The PARAD dismissed the complaint for lack of sufficient factual basis and held that the action was barred by the Statute of Limitations, having been commenced beyond the three-year prescriptive period under Section 38 of R.A. No. 3844. It also found that Lucila’s occupancy of Lot 13, Blk. 1 was unwarranted and ordered her to vacate, with provision for assistance if she chose to resettle outside the subdivision perimeter fence near the creek.

Lucila moved for reconsideration. On September 4, 2001, the PARAD issued an order reversing its earlier February 9, 2001 decision. The PARAD declared Lot 13, Block 1 as the lawful homelot of Lucila and ordered respondents to surrender transfer to Lucila for registration, and directed the Register of Deeds to transfer TCT No. T-463035 to Lucila. The order made no pronouncement as to costs and damages.

DARAB Ruling: Reinstatement of Dismissal

Respondents appealed to the Department of Agrarian Reform Adjudication Board (DARAB). On April 8, 2008, the DARAB reversed the PARAD’s September 4, 2001 order and reinstated the February 9, 2001 decision. The DARAB’s principal reasoning was that the tenancy relationship had been severed when the land Lucila once tenanted had been converted into non-agricultural use, specifically residential land. It then held that disturbance compensation had already been complied with because the P1,046,460.00 payment exceeded what was required under Section 36(1) of R.A. No. 3844 as amended and DAR AO No. 1, series of 1990.

The DARAB further held that, even if Lucila were still entitled to disturbance compensation of 1,000 square meters, the claim had prescribed. It found that the cause of action accrued in July 1993 but Lucila filed the action only in January 2000, well beyond the three-year limit. Finally, it characterized the PARAD’s reversal order as issued with grave abuse of discretion amounting to lack or excess of jurisdiction, particularly because the PARAD directed surrender and transfer of the entire subject area despite Lucila’s claim being only for one thousand square meters.

Lucila moved for reconsideration, which the DARAB denied on December 5, 2008.

Court of Appeals: Affirmation on Prescription and Lack of Merits

Lucila then filed a Petition for Review under Rule 43 before the Court of Appeals, assailing the DARAB’s April 8, 2008 decision.

In its October 30, 2009 Decision, the Court of Appeals affirmed the DARAB. It ruled that Lucila’s action had prescribed, relying on Section 38 of R.A. No. 3844 and the accrual of the cause of action in July 1993 when Lucila and her husband executed the notarized Malayang Salaysay acknowledging payment of P1,046,460.00.

The Court of Appeals also ruled that even assuming timeliness, Lucila’s claim lacked merit because the documentary evidence did not substantially prove any enforceable promise for additional compensation in the form of 1,000 square meters. It emphasized that the notarized Malayang Salaysay did not contain any stipulation about additional compensation via a 1,000-square meter lot. The Court of Appeals thus affirmed the DARAB.

Its February 16, 2010 Resolution denied Lucila’s motion for reconsideration.

The Supreme Court’s Ruling: Affirmance and Grounds

On review, the Supreme Court affirmed the Court of Appeals. It held that Lucila’s action had prescribed and that, in any event, the petition remained unmeritorious.

First, the Court applied Section 38 of R.A. No. 3844, which provides that any action to enforce a cause of action under the Code is barred unless commenced within three years after such cause of action accrued. It treated a cause of action as the act or omission violating another’s right and identified the accrual point as the execution of the notarized Malayang Salaysay dated July 1, 1993, where the Purificacion spouses relinquished tenancy rights in exchange for P1,046,460.00 representing disturbance compensation.

Lucila’s complaint was filed only on January 3, 2000, more than six years after the transaction acknowledged in the notarized document. The Supreme Court held that, because the prescriptive period under Section 38 had already run, Lucila’s action was barred by prescription.

Second, the Supreme Court found that Lucila had already received her fair share of disturbance compensation. It cited Section 16 of DAR AO No. 1, series of 1990, which requires disturbance compensation to be paid to affected tenants in amounts mutually agreed upon but not less than five times the average gross harvest value for the last five preceding calendar years, with compensation in kind possibly including free housing and homelots, subject to the DAR’s approval and monitoring of compliance.

Based on the DARAB’s findings, the Court agreed that the P1,046,460.00 paid on July 1, 1993 was already compliant with the legal requirement. It noted that the amount’s computation was not fully disclosed in the records, but it accepted the DARAB’s application of a factual assumption regarding average gross harvest and concluded that the cash paid was more than what the law required.

The Court further invoked a settled rule of deference to administrative fact-finding: the DARAB’s findings, when based on substantial evidence and affirmed by the appellate court, controlled unless there was grave abuse of discretion, fraud, or error of law, none of which obtained.

Third, the Supreme Court ruled that Lucila’s documentary submissions failed to rebut the effect of the Notarized Malayang Salaysay. It explained that the May 20, 1993 Letter did not categorically grant the 1,000-square meter portion to Lucila; it instead merely showed that respondents were considering an allocation, potentially as part of negotiations. It treated the letter as tentative rather than conclusive of an agreement that would obligate respondents to give additional land beyond the cash already received.

As to the conflict between the unnotarized and notarized narrations, the Court emphasized that notarized documents enjoy the presumptio

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