G.R. No. 158314 ; June 3, 2004
SAMAHAN NG MAGSASAKA SA SAN JOSEP, represented by DOMINADOR MAGLALANG, petitioner, vs. MARIETTA VALISNO, ADELA, AQUILES, LEANDRO, HONORIO, LUMEN, NICOLAS, all surnamed VALISNO; RANDY V. WAGNER, MARIA MARTA B. VALISNO, NOELITO VALISNO, MARY ANN L. VALISNO, PHILIP V. BRANZUELA and BRENDON V. YUJUICO; MA. CRISTINA VALISNO, BENEDICTO V. YUJUICO, GREGORIO V. YUJUICO and LEONORA V. YUJUICO, respondents.

FACTS

The case involves the 57-hectare land of the late Dr. Nicolas Valisno, Sr. in Nueva Ecija. Before the effectivity of Presidential Decree No. 27 in 1972, the land was subdivided and titled to his eight children and two mortgagees. A 12-hectare portion mortgaged to the Bantings was foreclosed and sold at public auction. In 1973, four grandchildren of Dr. Valisno—Ma. Cristina Valisno, Benedicto, Gregorio, and Leonora Yujuico—redeemed this 12-hectare portion, though titles were transferred only in 1998. During agrarian reform proceedings, the grandchildren applied for retention rights as landowners over this redeemed portion.
The Department of Agrarian Reform (DAR) Regional Director initially granted retention rights only to the seven children of Dr. Valisno, denying the grandchildren’s application. The DAR Secretary affirmed, ruling the redemption was not credible as three of the four redemptioners were minors in 1973 and thus lacked legal capacity. The Court of Appeals reversed this, recognizing the grandchildren’s rights. The petitioner farmers’ group, represented by former tenant Dominador Maglalang, appealed to the Supreme Court.

ISSUE

Whether the redemptioner-grandchildren are entitled to retention rights as landowners under the Comprehensive Agrarian Reform Law.

RULING

Yes, the Supreme Court affirmed the Court of Appeals and upheld the retention rights of the four redemptioner-grandchildren. The legal logic centers on the validity of the redemption and the consequent vesting of ownership. The Court clarified that a minor can validly redeem property; the transaction is not void but merely voidable, and can be ratified upon reaching majority age. The redemption in 1973 and the subsequent transfer of titles in 1998 effectively made the grandchildren the absolute owners of the 12-hectare portion.
As owners, they are entitled to the retention rights granted to landowners under Republic Act No. 6657 . Each is entitled to retain up to five hectares. Since the redeemed property totals only 12 hectares, or three hectares each, it is within the statutory limit. The Court emphasized that the right of retention is a constitutional guarantee for landowners, intended to mitigate the effects of compulsory land acquisition. Therefore, the DAR Secretary erred in denying their application based on the disputed validity of the redemption, as ownership was conclusively established by the titles issued in their names.