G.R. No. L-6229, L-6374, L-6378, L-6405 March 11, 1954
LUCIO LOPEZ, plaintiff-appellee, vs. ELIAS DE LA CRUZ, ET AL., defendants-appellants; FELICIANO TADEO, plaintiff-appellee, vs. CIPRIANO RODRIGUEZ y OTROS, defendants-appellants; PACITA ESLAYA VDA. DE VALINO, for herself and as administratrix of the Intestate Estate of the deceased Eleuterio Valino, plaintiff-appellee, vs. CONCORDIA NAYO y OTROS, defendants-appellants; HILARIO ESPIRITU, plaintiff-appellee, vs. CIPRIANO RODRIGUEZ and OTROS, defendants-appellants.

FACTS

These are four consolidated cases involving distinct parcels of land, different areas, different plaintiff-landowners, and different defendant-occupants. The defendants do not deny that the plaintiffs hold Torrens titles as absolute owners of the respective litigated lands, free from all liens and encumbrances. Despite this, the defendants refuse to recognize the plaintiffs as owners or to return the property, taking the attitude of possessing and enjoying another’s property without payment. The defendants’ justification is that these lands formed part of a large hacienda of the late Judge Simplicio del Rosario, of which they and about 500 others were tenants for many years. They have sought from various executive offices and Congress the expropriation of the hacienda for resale to the occupants as authorized by the Constitution. The hacienda was sold to private individuals in small lots by the late Del Rosario or his heirs or successors-in-interest. The defendants argue that the plaintiffs should not have bought portions of the hacienda because the defendants have a preference to acquire them, and thus they believe the plaintiffs are buyers in bad faith. They cannot or do not wish to pay in cash, even at cost price, because if the Government acquired the hacienda, the sale to occupants would be more bearable, being payable in equal installments over ten years. Their efforts with the executive and legislative departments have not yielded favorable results, but they hope to succeed in time.

ISSUE

Whether the defendants, as tenants, can lawfully refuse to recognize the Torrens titles of the plaintiffs and vacate the land based on their claim of a preferential right to purchase and their pending efforts for government expropriation and redistribution under social justice principles.

RULING

The Supreme Court ruled against the defendants and affirmed the lower court’s decisions. The Court held that under the prevailing law, the owner of private property has the right to enjoy and dispose of it, with the only limitations being those established by law. The owner has a right of action against the holder and possessor to recover it and to receive its fruits. The defendants’ claimed preferential right to purchase the land they occupy is not yet incorporated into Philippine law. A private contract of sale remains a free act, and an owner is not obliged to sell to a specific person in the absence of a prior contractual obligation. Unless some encumbrance appears on the Torrens title or is known to the buyer in some form, any person with legal capacity is free to buy the land. While the defendants cite principles of social justice from the Constitution, speeches, and writings of various advocates, as well as several laws aimed at realizing social justice, the Court emphasized that there is a great difference between word and deed, and no expropriation has yet taken place. The courts cannot and must not validly usurp legislative or executive functions, which would be the effect of acceding to the defendants’ pretensions in these cases. The defendants were ordered to vacate the lands and pay the reasonable value for their use and occupation, with legal interest from the due dates of payment and costs.