G.R. No. 170693 ; August 8, 2010
Emilia Micking Vda. De Coronel and Benjamin Coronel, Petitioners, vs. Miguel Tanjangco, Jr., Respondent.

FACTS

Respondent Miguel Tanjangco, Jr. filed a complaint for cancellation of Certificate of Land Transfer (CLT) and ejectment against petitioners Emilia Coronel and her son Benjamin before the DARAB. Tanjangco claimed ownership over three lots cultivated by the Coronels as agricultural lessees. He alleged that the parties executed a 1980 Kasunduan where, for a consideration, petitioners agreed to relinquish their tenancy rights and convert the land into fish farms, after which they leased a lot to third parties. Tanjangco demanded they vacate all lots. Petitioners countered that the lots were owned by Tanjangco’s father, that Emilia was a legitimate beneficiary under Operation Land Transfer holding a CLT, and that any relinquishment was void under agrarian laws. They also asserted that a prior MAR Order from 1986, which granted Tanjangco’s petition for retention and directed the cancellation of existing CLTs over Lot 38, was central to the case.

ISSUE

The core issue was whether petitioners, as CLT holders, could be lawfully ejected from the landholding based on the 1980 Kasunduan and the subsequent conversion of the land use.

RULING

The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals and reinstating the DARAB Central Office decision. The legal logic centered on the indefeasibility of a tenant-farmer’s rights under agrarian reform laws. The Court held that the 1980 Kasunduan, wherein petitioners purportedly relinquished their rights, was void ab initio. Such voluntary surrenders or transfers of rights by farmer-beneficiaries are strictly prohibited under Presidential Decree No. 27 and related agrarian laws to protect them from exploitation. The mere conversion of the land into fishponds did not automatically extinguish the tenurial relationship, as the law requires specific, authorized grounds for ejectment which were not present. Furthermore, the issuance of the CLT to Emilia Coronel vested in her a provisional ownership right, making her possession lawful. The Court emphasized that the government’s agrarian reform program aims for security of tenure, and any agreement contravening this policy is invalid. Consequently, Tanjangco’s action for ejectment had no legal basis, and petitioners were entitled to maintain possession as beneficiaries.