GR 132073; (September, 2006) (Digest)

G.R. No. 132073 & G.R. No. 132361; September 27, 2006
REMMAN ENTERPRISES, INC., petitioner, vs. THE HON. COURT OF APPEALS, HON. ERNESTO D. GARILAO, in his capacity as SECRETARY OF THE DEPT. OF AGRARIAN REFORM and EDUARDO ADRIANO, et al., respondents.

EDUARDO ADRIANO, et al., petitioners, vs. HON. COURT OF APPEALS, REMMAN ENTERPRISES, INC., and HON. ERNESTO D. GARILAO, in his capacity as SECRETARY OF AGRARIAN REFORM, respondents.

FACTS

Remman Enterprises, Inc. (REMMAN) applied with the DAR for exemption from CARP coverage over 17 parcels of land in Dasmariñas, Cavite, which it purchased from the Saulog family. REMMAN supported its application with certifications that the land was within a residential zone and was not irrigated. The DAR Secretary denied the application, ruling REMMAN lacked personality to file as the deed of sale was unregistered, and that the land was covered by Operation Land Transfer under P.D. No. 27, with 24 farmer-beneficiaries holding emancipation patents. The Secretary also initially found the land to be irrigated.
Upon reconsideration, the DAR Secretary modified the order, applying P.D. No. 27 retention limits to the co-owners of the Saulog family. He computed the areas each co-owner could retain, ordering that farmer-tenants on retained areas could remain or accept disturbance compensation. REMMAN and the farmer-beneficiaries (Eduardo Adriano, et al.) separately challenged this order before the Court of Appeals, which dismissed both petitions. They subsequently elevated the case to the Supreme Court via petitions for review.

ISSUE

The core issue is whether the DAR Secretary correctly applied P.D. No. 27 retention limits to the subject landholdings and whether the subsequent issuance of emancipation patents to farmer-beneficiaries was valid.

RULING

The Supreme Court denied the petitions and affirmed the Court of Appeals. The legal logic rests on the conclusive finding that the subject lands were primarily devoted to rice and corn and worked by tenant-farmers as of 21 October 1972, the effectivity date of P.D. No. 27. This factual finding by the DAR Secretary, supported by evidence, is binding and conclusive. Consequently, the landholding was indisputably covered by the Operation Land Transfer program under P.D. No. 27.
The Court emphasized that the issuance of emancipation patents to the farmer-beneficiaries was the operative act of transferring ownership pursuant to P.D. No. 27. These patents, issued in 1989, vested ownership in the farmers. Therefore, the Saulog family’s subsequent sale of the land to REMMAN in 1995 was void because they were no longer the owners—title had already been transferred to the farmer-beneficiaries. REMMAN thus acquired no rights over the property. The DAR Secretary correctly applied the P.D. No. 27 retention limits to determine the areas the Saulog co-owners could retain from the tenanted rice and corn land, but this computation was ultimately mooted by the prior and valid transfer of ownership through the emancipation patents. The exemption or conversion application was properly denied.