Case Summary (G.R. No. 202830)
Procedural History
On January 17, 1996, Ricardo Gacula petitioned for the cancellation of CLOAs issued to 47 individual petitioners. This petition was dismissed without prejudice by the Provincial Agrarian Reform Adjudicator (PARAD) on October 23, 1996, due to a pending application for exemption from the Comprehensive Agrarian Reform Program (CARP) made by Gacula. Despite the appeal's dismissal, Gacula continued to pursue the matter, culminating in various orders and motions through subsequent years.
Key Orders and Appeals
In 1998, the Department of Agrarian Reform (DAR) Secretary Ernesto Garilao granted Gacula's application for exemption, only for this decision to be overturned in 1999 by then-Secretary Horacio Morales. A crucial point emerged on October 15, 2001, when DARAB Director Delfin B. Samson asserted the finality of the Secretary’s reversal. Gacula’s appeal was dismissed again in 2001, but he later filed a Manifestation expressing disinterest in his appeal while requesting the implementation of earlier decisions. On November 27, 2003, Adjudicator Salcedo issued an order canceling the petitioners' CLOAs, which the petitioners disputed as being made without due process.
Allegations of Due Process Violation
The petitioners contended that Adjudicator Salcedo's order was rendered without proper notice and hearing. They argued that the cancellation was a product of Gacula's mere Manifestation instead of a formal petition, thereby lacking the necessary legal foundation for such a ruling. The petitioners claimed they had occupied the land since the 1950s and had received their CLOAs in 1992, affirming their long-standing rights.
Court of Appeals and Petition for Review
Petitioners sought recourse in the Court of Appeals after their urgent motion to restrain the execution of Salcedo’s order was dismissed. Their petition was met with various procedural deficiencies, which the CA cited in dismissing the appeal on May 4, 2012, and later on July 12, 2012, which led to the current issue brought before the Supreme Court.
Supreme Court's Ruling
The Supreme Court found merit in the petitioners’ contentions, emphasizing the necessity of adhering to substantial justice over procedural technicalities. The Court noted that while there were indeed lapses in procedural compliance, these should not overshadow the substantive issues raised by the petitioners. The Supreme Court highlighted the inconsistency and lack of legal gr
...continue readingCase Syllabus (G.R. No. 202830)
Overview
- The case revolves around a petition for review on certiorari filed by the petitioners against the resolutions of the Court of Appeals (CA) which dismissed their appeal concerning the cancellation of Certificates of Land Ownership Award (CLOA) issued to them.
- The petitioners are comprised of multiple spouses and individuals who were beneficiaries of the Comprehensive Agrarian Reform Program (CARP) concerning a specific 30-hectare land in Cagayan de Oro City.
- The primary contention is the alleged improper cancellation of their CLOAs without due process.
Antecedent Facts
- Initial Petition: On January 17, 1996, Ricardo Gacula filed a petition to cancel the CLOAs of the petitioners.
- Dismissal of Petition: The petition was dismissed without prejudice on October 23, 1996, due to a pending application for exemption from CARP by Gacula.
- Exemption Granted: On January 14, 1998, the DAR Secretary granted an exemption, which led to subsequent appeals and motions for reconsideration from the petitioners, with varying outcomes over the years.
- Final Cancellation: On November 27, 2003, Adjudicator Abeto Salcedo, Jr. issued an order cancelling the petitioners' CLOAs based on Gacula's manifestation, despite the petitioners' claims of lack of proper notice and hearing.
Legal Proceedings and Motions
- Entry of Appearance and Appeal: After Salcedo’s order, the petitioners filed an entry of appearance and notice of appeal, which was denied due to improper substitution of counsel.
- Urgent Motion: The petitioners submitted an urgent motion to