GR 116863; (February, 1998) (Digest)
March 11, 2026GR 202676; (December, 2019) (Digest)
March 11, 2026G.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 different 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, possessing and enjoying the property of others 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. 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 also state 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 yet 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
No. The appealed judgments are affirmed. The Court held that while the aspirations for social justice cited by the defendants from speeches, writings, the Constitution, and various laws are noble, there is a significant difference between word and deed. No expropriation has yet taken place. The defendants’ reasoning and attitude are based on an assumption not yet achieved. The courts cannot and must not validly usurp legislative or executive functions, which is what acceding to the defendants’ pretensions would amount to. The prevailing law favors the owner of private property. Article 428 of the Civil Code states the owner has the right to enjoy and dispose of a thing, with no other limitations than those established by law, and has a right of action against the holder and possessor to recover it, as well as to receive its fruits. The defendants’ claimed preferential right to purchase is not yet incorporated into Philippine laws. A private contract of sale remains a free act; an owner is not obliged 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 form, any person with legal capacity is free to buy the land. While morally the world might have made common cause with the tenants, this is not yet law that the courts can impose. The amounts adjudged as the reasonable value for the use and occupation of the lands are not questioned. The appealed judgments are confirmed, with legal interest on the adjudged sums from the expiration of their respective payment deadlines, and with the costs of this instance.
