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    Vinzons-Magana Vs Estrella

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    Athena Santos
    The document discusses a case where a landowner petitioned to terminate a lease agreement with a tenant farmer. The government then issued a certificate of land transfer to the farmer without compensating the landowner. The Supreme Court ruled this was unconstitutional as it amounted to confiscation of private property without due process or just compensation.

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    Vinzons-Magana Vs Estrella

    Uploaded by

    Athena Santos
    482 views1 page
    The document discusses a case where a landowner petitioned to terminate a lease agreement with a tenant farmer. The government then issued a certificate of land transfer to the farmer without compensating the landowner. The Supreme Court ruled this was unconstitutional as it amounted to confiscation of private property without due process or just compensation.

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    Agrarian Law

    Original Title

    Vinzons-Magana vs Estrella

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    The document discusses a case where a landowner petitioned to terminate a lease agreement with a tenant farmer. The government then issued a certificate of land transfer to the farmer without compensating the landowner. The Supreme Court ruled this was unconstitutional as it amounted to confiscation of private property without due process or just compensation.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    482 views1 page

    Vinzons-Magana Vs Estrella

    Uploaded by

    Athena Santos
    The document discusses a case where a landowner petitioned to terminate a lease agreement with a tenant farmer. The government then issued a certificate of land transfer to the farmer without compensating the landowner. The Supreme Court ruled this was unconstitutional as it amounted to confiscation of private property without due process or just compensation.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    G.R. No.

    L-60269 September 13, 1991


    ENGRACIA VINZONS-MAGANA, petitioner, vs. HONORABLE CONRADO ESTRELLA IN HIS CAPACITY AS
    MINISTER OF AGRARIAN REFORM, SALVADOR PEJO, AS REGIONAL DIRECTOR, MINISTRY OF
    AGRARIAN REFORM, and JUANA S. VDA. DE PAITAN, respondents.

    FACTS:
    Magana is the owner of a parcel of riceland situated in the barrio of Talisay, Camarines Norte. The said
    riceland was tenanted by the late Domingo Paitan, husband of private respondent herein, Juana Vda. de
    Paitan, under an agricultural leasehold agreement.
    On October 20, 1977, Magana filed a petition for the termination of the leasehold agreement allegedly
    due to (1) non-payment of rentals; (2) inability and failure of Domingo Paitan to do the tilling and
    cultivation of the riceland due to his long illness; and (3) subleasing of the landholding to third parties.
    Presiding Judge of the Court of Agrarian Relations, Judge Juan Llaguno, referred the case to the
    Secretary of the Department of Agrarian Reform for certification as to whether or not it was proper for
    trial in accordance with Presidential Decree No. 316, (Ibid., pp. 10-11), but said office failed to act upon
    the request for certification, for a period of more than three (3) years.
    Instead on July 10, 1980, the riceland was placed under the Land Transfer Program by virtue of
    Memorandum Circular No. 11, Series of 1978, which implemented Letter of Instructions No. 474, which
    placed all tenanted ricelands with areas of seven hectares or less belonging to landowners who own
    agricultural lands of more than seven hectares in aggregate areas under the Land Transfer Program of
    the government.
    A certificate of Land Transfer was finally awarded in favor of Domingo Paitan. As a consequence thereof,
    the rentals were no longer paid to Magana but were deposited instead with the Land Bank and credited
    as amortization payments for the riceland. Apparently aggrieved by this turn of events, Magana took the
    present recourse.

    ISSUE:
    WON the issuance of Certificate of Land Transfer to Domingo Paitan is invalid and unconstitutional.

    HELD: Yes.
    The issuance of Certificate of Land Transfer to Domingo Paitan without first expropriating said property
    to pay petitioner landowner the full market value thereof before ceding and transferring the land to
    Paitan and/or heirs, is invalid and unconstitutional as it is confiscatory and violates the due process
    clause of the Constitution.
    The mere issuance of the certificate of land transfer does not vest in the farmer/grantee ownership of
    the land described therein. At most, the certificate merely evidences the government's recognition of
    the grantee as the party qualified to avail of the statutory mechanisms for the acquisition of ownership
    of the land titled by him as provided under Presidential Decree No. 27. Neither is this recognition
    permanent nor irrevocable. Thus, failure on the part of the farmer/grantee to comply with his obligation
    to pay his lease rentals or amortization payments when they fall due for a period of two (2) years to the
    landowner or agricultural lessor is a ground for forfeiture of his certificate of land transfer.
    Should Magana fail to agree on the price of her land as fixed by the DAR, she can bring the matter to the
    court of proper jurisdiction. Likewise, failure on the part of the farmer/grantee to pay his lease rentals or
    amortization payments for a period of two (2) years is a ground for forfeiture of his certificate of land
    transfer.

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