G.R. No. 226863, February 19, 2020
Heirs of Valeriano C. Dela Corta, Sr., namely: Pedro C. Dela Corta, Valeriano C. Dela Corta, Jr., Roberto C. Dela Corta, Temoteo C. Dela Corta, Emma C. Dela Corta, Anita C. Dela Corta, Adelaida D. Otero, and Alejandra Cose Dela Corta for herself, all represented by Pedro C. Dela Corta, Petitioners, v. Rebecca Alag-Pitogo, represented by Oscar Pitogo, Respondent.
FACTS
The case involves Lot No. 50, BSD-08-000105 (OLT), a portion of Lot 11421, Cad. 256, in Brgy. Curva, Ormoc City, Leyte, with an area of 29,010 square meters. Pursuant to Presidential Decree No. 27, the subject lot was awarded to the late Valeriano C. Dela Corta, Sr. on December 19, 1974, through Emancipation Patent No. 443564. Transfer Certificate of Title No. 3247 was issued in his favor on February 5, 1998, after his death on June 12, 1989. On October 2, 2006, respondent Rebecca Alag-Pitogo filed a petition for reallocation of the subject lot before the DAR-Region VIII, arguing that the lot was erroneously awarded to Valeriano. She based her claim on a decision in CAR Case No. 1726 by the Regional Trial Court (RTC), Branch 12, Ormoc City, which allegedly disqualified Valeriano as a farmer beneficiary and declared her mother, Guillerma Alag, and Carlos Sabino as the qualified beneficiaries for specific portions. Guillerma allegedly waived her rights over a 1.1000-hectare portion in favor of the respondent. The DAR-Region VIII granted the petition for reallocation on August 9, 2007, confirming the respondent’s qualifications and ordering the cancellation of Valeriano’s title. Petitioner Pedro Dela Corta, one of Valeriano’s heirs, filed a motion for reconsideration, which was denied. The DAR-Region VIII’s Order became final, and a Certificate of Finality was issued on October 22, 2008. Subsequently, on March 11, 2009, the respondent filed a petition before the DARAB for the cancellation of Valeriano’s Emancipation Patent. The DARAB Regional Adjudicator granted the petition on October 5, 2009, ordering the cancellation of the patent and the generation of a new title in favor of the respondent. Pedro appealed to the DARAB Central Office, which dismissed the appeal on May 8, 2013. The petitioners then filed a Petition for Review with the Court of Appeals, which denied the appeal and affirmed the DARAB Central Office’s Decision on August 27, 2015. A Motion for Reconsideration was denied on July 20, 2016.
ISSUE
The primary issue resolved was whether the Court of Appeals erred in affirming the decisions of the DARAB and DAR-Region VIII, which ordered the reallocation of the land and cancellation of Valeriano’s Emancipation Patent in favor of the respondent, despite petitioners’ claims of lack of jurisdiction, denial of due process, and that the other heirs were indispensable parties not impleaded.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals’ decision. The Court held that the factual findings of the DAR-Region VIII, DARAB Regional Adjudicator, and DARAB Central Office, as affirmed by the Court of Appeals, are binding and supported by substantial evidence. It emphasized that the RTC decision in CAR Case No. 1726 had already disqualified Valeriano as a farmer beneficiary, and this finding was final and binding on his heirs. The Court ruled that the petitioners, as heirs of Valeriano, were not indispensable parties in the cancellation proceeding because Valeriano had already lost any interest or right over the subject farmlot due to the final RTC decision disqualifying him. Consequently, his heirs could not derive any rights from him. The Court also noted that the DAR-Region VIII’s Order granting reallocation had attained finality, and Pedro’s appeal to the DAR Secretary was filed out of time, thus producing no legal effect. The Court found no merit in the petitioners’ claims of lack of jurisdiction or denial of due process.
