Case Digests in AgroSoc

LAND BANK OF THE PHILIPPINES, Petitioner,
vs. HON. ELI G. C. NATIVIDAD and JOSE R. CAGUIAT

G.R. No. 127198. May 16, 2005
FACTS:
Private respondents filed a petition before the trial court for the determination of just
compensation for their agricultural lands, which were acquired by the government
pursuant to PD 27. The RTC ordered Land Bank and DAR to pay respondents' land for
P30 per square meters. Land Bank was not able to file its motion for reconsideration on
time because the motion filed by its counsel lacked a notice of hearing. Land Bank
argues that the failure of its counsel is due to intense work-pressure and constitutes
excusable negligence, so the trial court should have heard the relief in accordance with
Sec 1 of Rule 38 of the 1997 Rules of Civil Procedure. Land Bank also argues that
respondents failed to exhaust administrative remedies when they filed a petition for the
determination of just compensation directly with the trial court because they should
have first sought reconsideration of the DAR's valuation of their properties.
Issues:
1. Whether or not counsel's failure to include a notice of hearing constitutes excusable
negligence entitling Land Bank to a relief from judgment.
2. WON respondents should have sought reconsideration from DAR.
Held:
The petition is unmeritorious.Reasoning: Land Bank's argument that its counsel
committed an excusable negligence when he was not able to file the motion on time is
untenable. Primary jurisdiction is vested in the DAR to determine in a preliminary
manner the just compensation for the lands taken under the agrarian reform program,
but such determination is subject to challenge before the courts. The resolution of just
compensation cases for the taking of lands under agrarian reform is, after all, essentially
a judicial function.
Thus, the trial did not err in taking cognizance of the case as the determination of just
compensation is a function addressed to the courts of justice.
Alita v CA
Facts:
Private respondents' predecessors-in-interest acquired the subject parcel of lands
through homestead patent under the provisions of Commonwealth Act No. 141. Private
respondents herein are desirous of personally cultivating these lands, but petitioners
refuse to vacate, relying on the provisions of P.D. 27 and P.D. 316. On June 18, 1981,
private respondents instituted a complaint for the declaration of P.D. 27 and all other
Decrees, Letters of Instructions and General Orders issued in connection therewith as
inapplicable to lands obtained through homestead law. The RTC dismissed the
complaint but on motion for reconsideration it declared that P.D. 27 is not applicable to
homestead lands. On appeal to the CA, the decision of the RTC was sustained.
Issue:
Whether or not lands acquired through homestead law are covered by CARP
Held:
Petitioners is correct in saying that P.D. 27 decreeing the emancipation of tenants
from the bondage of the soil and transferring to them ownership of the land they till is a
sweeping social legislation, a remedial measure promulgated pursuant to the social
justice precepts of the Constitution. However, such contention cannot be invoked to
defeat the very purpose of the enactment of the Public Land Act or Commonwealth Act
No. 141. The Philippine Constitution likewise respects the superiority of the
homesteaders' rights over the rights of the tenants guaranteed by the Agrarian Reform
statute. Provided, that the original homestead grantees or their direct compulsory heirs
who still own the original homestead at the time of the approval of this Act shall retain
the same areas as long as they continue to cultivate said homestead.
Estribillo v DAR
Facts:
Private respondent Hacienda Maria Inc. requested that 527.8308 hectares of its
landholdings be placed under the coverage of Operation Land Transfer. Receiving
compensation therefor, HMI allowed petitioners and other occupants to cultivate the
landholdings so that the same may be covered under Agrarian Reform Program. In
1982, a final survey over the entire area was conducted and approved. From 1984 to
1988, the corresponding TCTs and EPs covering the entire 527.8308 hectares were
issued to petitioners, among other persons. In December 1997, HMI filed with RARAD
petitions seeking the declaration of erroneous coverage under Presidential Decree No.
27 of 277.5008 hectares of its former landholdings. HMI claimed that said area was not
devoted to either rice or corn, that the area was untenanted, and that no compensation
was paid therefor. RARAD rendered a decision declaring as void the TCTs and EPs
awarded to petitioners because the land covered was not devoted to rice and corn, and
neither was there any established tenancy relations between HMI and petitioners.
Petitioners appealed to the DARAB which affirmed the RARAD Decision. On appeal to
the CA, the same was dismissed. Petitioners contended that the EPs became indefeasible
after the expiration of one year from their registration.
Issue:
Whether or not EPs have become indefeasible one year after their issuance
Held:
After complying with the procedure in Section 105 of Presidential Decree No.
1529, otherwise known as the Property Registration Decree where the DAR is required
to issue the corresponding certificate of title after granting an EP to tenant-farmers who
have complied with Presidential Decree No. 27, the TCTs issued to petitioners pursuant
to their EPs acquire the same protection accorded to other TCTs. The certificate of title
becomes indefeasible and incontrovertible upon the expiration of one year from the date
of the issuance of the order for the issuance of the patent. Lands covered by such title
may no longer be the subject matter of a cadastral proceeding, nor can it be decreed to
another person.

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LAND BANK OF THE PHILIPPINES, Petitioner,

vs. HON. ELI G. C. NATIVIDAD and JOSE R. CAGUIAT

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