G.R. No. 143362 ; June 27, 2006
CYNTHIA V. OMADLE and ANGELITO ALISEN, Petitioners, vs. SPOUSES WILFREDO and ROGELIA B. CASUNO, Respondents.

FACTS

Petitioner Cynthia Omadle is an heir of the late Francisco Villa, owner of Lot 406 in Bukidnon. Respondents, Spouses Casuno, were once tenants of Villa on a portion of this lot. On December 18, 1987, the Department of Agrarian Reform (DAR) awarded that portion to the respondents, issuing Emancipation Patent No. A-042463 and a corresponding Transfer Certificate of Title (TCT). The respondents later mortgaged the property. Omadle redeemed the land from the mortgagees and caused the eviction of the Casunos. Consequently, on July 10, 1991, the Casunos filed a Complaint for Recovery of Possession and Ownership before the DAR Adjudication Board (DARAB).
Omadle contended that the land was exempt from land reform as part of her retention limit, that the Casunos violated their Certificate of Land Transfer by mortgaging the lot and paid amortizations only once, and that the action had prescribed. The DARAB Regional Adjudicator initially dismissed the complaint, ruling the land was within the heirs’ retention rights. On appeal, the DARAB Central Office reversed, finding the heirs had voluntarily submitted the land for coverage and that the issuance of the emancipation patent and title vested ownership in the Casunos.

ISSUE

Whether the respondents, as beneficiaries issued an emancipation patent and title, have become absolute owners of the landholding, thereby barring their dispossession by the landowner’s heir.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision upholding the DARAB. The Court ruled that the issuance of Emancipation Patent No. A-042463 and TCT No. ET-5184 to the Casunos on December 18, 1987, transformed their status from mere tenants to absolute owners of the landholding. This issuance presupposes compliance with the requirements under agrarian laws and conclusively entitles the grantee to the rights of absolute ownership. Consequently, the Casunos could no longer be dispossessed.
The legal logic is clear: once an emancipation patent is issued, the grantee’s right of ownership becomes vested and fixed. Any claim by the landowner for unpaid amortizations is properly directed against the Land Bank of the Philippines, which finances the program, and not against the farmer-beneficiary. Furthermore, the prescriptive period under Section 38 of Republic Act No. 3844 does not apply, as the Casunos’ cause of action arises from their vested ownership rights, not from a tenancy relationship. Their act of mortgaging the property, sanctioned under Presidential Decree No. 315 to finance agricultural production, did not revert ownership or justify dispossession by the former landowner.