GR L 6229; (March, 1954) (4) (Digest)
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 refused 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 purchased 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. The defendants cite speeches and writings on social justice, constitutional provisions on social justice, and various laws aimed at realizing social justice to support their position.
ISSUE
Whether the defendant-occupants, who are former tenants of a large hacienda, can lawfully refuse to recognize the title and ownership of the plaintiffs who purchased subdivided lots from that hacienda, and refuse to vacate the land or pay for its use and occupation, based on their claim of a preferential right to purchase and the principles of social justice, in the absence of actual government expropriation and redistribution.
RULING
The appealed judgments are affirmed. The defendants are ordered to vacate the lands they respectively occupy and to pay the reasonable value for the use and occupation, with legal interest on the adjudged amounts from the expiration of the respective payment deadlines, and with costs. The Court held that the law currently in force favors the owner of private property. Under Article 428 of the Civil Code, the owner has the right to enjoy and dispose of the property, subject only to limitations established by law, and has a right of action against the holder and possessor to recover it, as well as the right to collect its fruits. The defendants’ claimed preferential right to purchase the lots they occupy is not yet incorporated into Philippine law. A private contract of sale remains a free act; the owner is not obligated to sell to a specific person in the absence of a pre-existing obligation. Unless some encumbrance appears on the Torrens title or is known to the buyer in some legal form, any person with legal capacity is free to purchase the land. While the defendants’ aspirations for social justice through land reform may be morally compelling, these are not yet law that the courts can impose. The courts cannot and must not validly usurp legislative or executive functions, which is what acceding to the defendants’ pretensions would amount to. There has been no expropriation yet; the defendants’ reasoning and attitude are based on an assumption not yet achieved.