GR 138979; (October, 2000) (Digest)
G.R. No. 138979 ; October 9, 2000
ERNESTO BUNYE, petitioner, vs. LOURDES AQUINO, CITA AQUINO and ROBERTO AQUINO, respondents.
FACTS
Bartolome Aquino was instituted as a tenant in 1967 over a 16,974.50 square meter agricultural lot owned by Zoilo Bunye. In 1970, Zoilo dispossessed Bartolome of 14,474.50 square meters for commercial use without paying disturbance compensation, allowing him to remain on only 2,500 square meters with a promise of a homelot. Bartolome secured a 1976 Court of Appeals decision affirming his tenancy status over this 2,500-square-meter portion. In 1986, the Minister of Agrarian Reform approved the conversion of this 2,500-square-meter area to residential/commercial use upon petitioner Ernesto Bunye’s (Zoilo’s son) application. Bartolome died in 1988. Petitioner later ejected respondents (Bartolome’s heirs) from 2,000 square meters, leaving them in possession of a 500-square-meter homelot.
Respondents filed a complaint before the Regional Agrarian Reform Adjudicator (RARAD), asserting a right to the 500-square-meter homelot as compensation for the loss of the entire original landholding. The RARAD and the DARAB ruled that the 1986 conversion extinguished the agricultural leasehold relationship before Bartolome’s death; thus, no tenancy rights devolved to the heirs. Respondents were entitled only to disturbance compensation for the 2,500 square meters. Due to absent production data, the RARAD alternatively awarded a 75-square-meter homelot. The Court of Appeals, while upholding the 75-square-meter award, erroneously held respondents were entitled to disturbance compensation for the entire original 16,974.50 square meters.
ISSUE
Whether respondents are entitled to disturbance compensation for the entire 16,974.50 square meters originally tenanted by their father.
RULING
No. The Supreme Court reinstated the Court of Appeals’ November 26, 1998 Decision but modified it by limiting the disturbance compensation to the 2,500-square-meter portion. The Court clarified that the claim for disturbance compensation for the 14,474.50 square meters from which Bartolome was dispossessed in 1970 had long prescribed. Bartolome’s 1973 CAR case sought only recognition of his tenancy over the remaining 2,500 square meters, not compensation for the earlier dispossession. Under Section 38 of Republic Act No. 3844 , an action to enforce a cause of action under the Code must be commenced within three years from its accrual. No such claim was made from 1970 until 1995; thus, it was barred. Consequently, respondents’ entitlement is confined to disturbance compensation for the dispossession from the 2,500 square meters. In the absence of harvest data to compute this compensation, the award of a 75-square-meter homelot as an equitable alternative relief was affirmed as reasonable.