GR L 73319; (December, 1987) (Digest)
G.R. No. L-73319 December 1, 1987
ENRIQUE ANTONIO, GREGORIO MARQUEZ, FELIPE BAGAY, ROSITA SANDIL and ELENA VDA. DE BAGAY, petitioners, vs. HON. CONRADO F. ESTRELLA, Office of the President, BENEDICTO ZAFRA, RAFAEL ZAFRA, CELSO ZAFRA, ALEJANDRO ZAFRA, JR., ANTONIA ONGAGUIT and JAIME C. JOAQUIN, respondents.
FACTS
Petitioners are tenant-farmers who were issued Certificates of Land Transfer (CLTs) in 1981 covering landholdings in Balagtas, Bulacan, pursuant to Presidential Decree No. 27. Private respondents, who are relatives of the original landowners, filed a petition for exemption from Operation Land Transfer (OLT) and for the recall of the CLTs. They claimed that the subject lands, with an aggregate area of 52.7 hectares, were sold to them in separate deeds executed on July 13, 1972, prior to PD 27. Each parcel sold to an individual respondent was less than seven hectares. They argued the tenants knew of the sales and had been paying rentals to them as new owners. The Minister of Agrarian Reform granted the petition and recalled the CLTs, a decision affirmed by the Office of the President.
ISSUE
Whether the subject landholdings are exempt from the compulsory coverage of Operation Land Transfer under PD 27.
RULING
The Supreme Court dismissed the petition and affirmed the administrative decisions. The legal logic is anchored on the explicit landholding ceiling under PD 27. The decree applies only to tenanted rice or corn lands where the landowner retains more than seven hectares. The Court found that the sales to private respondents, executed prior to PD 27, resulted in each respondent owning less than seven hectares. Therefore, their individual landholdings fell outside the compulsory coverage of OLT. The Court rejected the petitioners’ argument that the unregistered status of the 1972 sales at the time of PD 27’s effectivity invalidated the transfers for agrarian reform purposes. It noted the tenants were notified of the sales, binding them to the new owners. The payments made to the Land Bank were correctly characterized as mere “advance deposits” that could be withdrawn, not as conclusive amortization payments, since no valid compulsory sale under PD 27 could exist where the law’s coverage threshold was not met. The findings of the administrative agencies, being supported by substantial evidence, were accorded respect and finality.