Case Summary (G.R. No. 191359)
Dispute Overview
The crux of Lucila's petition is her assertion that she is entitled to an additional 1,000 square meters of land as disturbance compensation, in addition to the P1,046,460.00 she received following the sale of the property. Lucila contends a mutual agreement existed between her and the respondents, allowing her to retain a portion of the land after relinquishing her tenancy rights. This disagreement ultimately led her to file a Complaint for Disturbance Compensation after being instructed to vacate the property.
Legal Proceedings and Evidence Presented
In her claim, Lucila relied on two documents: a letter dated May 20, 1993, from Atty. Villanueva confirming the allocation of a 1,000-square meter portion for the Purificacion spouses, and an unnotarized Malayang Salaysay, emphasizing her and her husband's voluntary exit from the tenancy in exchange for compensation. However, Gobing countered that the compensation already paid exceeded their legal obligations under applicable agricultural law.
Rulings by the Agrarian Reform Adjudicator and DARAB
Initially, the Provincial Agrarian Reform Adjudicator (PARAD) sided with Lucila, declaring the 1,000-square meter lot as her lawful homelot. Nonetheless, after the respondents appealed, the Department of Agrarian Reform Adjudication Board (DARAB) reversed PARAD’s decision. It determined that the tenancy had been effectively severed when the land was converted to non-agricultural use, thereby negating any rights Lucila held over the property. Furthermore, the DARAB noted that the disturbance compensation already paid significantly exceeded the required legal minimum.
Court of Appeals Decision
Upon further appeal to the Court of Appeals, the appellate court upheld DARAB's findings, concluding that Lucila’s claim had already prescribed per the three-year statute of limitations stipulated in Section 38 of the Agricultural Land Reform Code (RA No. 3844). The Court found that sufficient evidence was not provided to substantiate Lucila’s assertion that the additional 1,000 square meters were part of the negotiated disturbance compensation.
Supreme Court's Ruling
In affirming the decisions of the lower courts, the Supreme Court reiterated the applicability of the statute of limitations and the regularity of notarized documents, establishing that the notarial acts by PARAD should be presumed valid. T
...continue readingCase Syllabus (G.R. No. 191359)
Case Overview
- This case involves a Petition for Review challenging a Decision by the Court of Appeals (CA) dated October 30, 2009, which denied Lucila Purificacion's claim for an additional 1,000-square meter lot as Disturbance Compensation, on top of the P1,046,460.00 already received.
- The CA also denied her Motion for Reconsideration on February 16, 2010.
Antecedents
- A 35,882 square meter agricultural land, covered by Transfer Certificate of Title No. T-252445, was owned by the Villanueva family, with Lucila and her late husband, Jacinto Purificacion, serving as tenants.
- In May 1993, Atty. Jaime Villanueva sold 33,882 square meters of this land to Charles Gobing, who subsequently converted it into a residential subdivision named Gold Lane Subdivision.
- On July 1, 1993, Atty. Villanueva paid the Purification spouses P1,046,460.00 as disturbance compensation.
- Lucila claimed that an additional agreement existed, stipulating the allocation of a 1,000 square meter portion for them, where their house was located.
Evidence Presented by Lucila
- Lucila presented two primary pieces of evidence to support her claim for the 1,000 square meter lot:
- May 20, 1993 Letter: This letter confirmed the agreement regarding the allocation of the 1,000 square meters.
- Unnotarized Malayang Salaysay: This document contained a declaration of the agreement made between the Purification spouses and the respondents for the disturbance compensat